A.M. No. RTJ-06-2010, January 30, 2008
Marissa R. Mondala, Legal Researcher, Regional Trial Court, Branch 136, Makati City, Complainant, vs. Presiding Judge Rebecca R. Mariano, Regional Trial Court, Branch 136, Makati City, Respondent.

FACTS

This administrative matter originated from a complaint against Judge Rebecca R. Mariano. In a prior Decision dated January 25, 2007, the Court found her guilty of misrepresenting that she had decided a specific case and of making inaccurate entries in monthly reports. She was fined P40,000.00, and her motion for reconsideration was denied with finality on February 27, 2007. Subsequently, the Office of the Court Administrator (OCA) submitted a Memorandum dated January 31, 2007, detailing the results of a judicial audit and physical inventory of pending cases in Judge Mariano’s court. The audit revealed numerous cases requiring immediate action, including cases without initial action, cases not set for hearing, cases stalled due to non-compliance, unresolved pending motions, and cases submitted for decision beyond the reglementary period.
Based on this subsequent audit, the Court, in a Resolution dated July 3, 2007, adjudged Judge Mariano administratively liable for undue delay in rendering decisions and orders and imposed an additional fine of P20,000.00. She was also directed to decide the backlogged cases with dispatch. Judge Mariano filed a Motion for Reconsideration, arguing that the infractions cited in the July 3, 2007 Resolution were the same ones for which she had already been fined P40,000.00 in the January 25, 2007 Decision. She also sought reconsideration of the initial P40,000.00 fine, citing mitigating circumstances like her long public service, failing health, and impending retirement.

ISSUE

Whether the fine of P20,000.00 imposed in the July 3, 2007 Resolution constitutes double jeopardy or an impermissible second penalty for the same set of infractions already penalized in the January 25, 2007 Decision.

RULING

The Court partly granted the Motion for Reconsideration. The legal logic centers on the prohibition against double punishment for the same act. The Court examined the records and found that the administrative infractions for which the additional P20,000.00 fine was imposed in the July 3, 2007 Resolution were indeed the same infractions—specifically, the undue delay and failure to decide cases within the reglementary period—that formed the basis of the earlier P40,000.00 penalty in the January 25, 2007 Decision. The subsequent OCA audit and memorandum merely provided a detailed inventory and confirmation of the very delays and backlogs that constituted the original offense. Therefore, imposing a second fine for the same factual basis and legal violation was improper. Consequently, the Court set aside the July 3, 2007 Resolution and the additional P20,000.00 fine. Regarding the initial P40,000.00 fine, the Court noted that the motion for its reconsideration had already been denied with finality and the fine had been paid, rendering that matter closed and immutable.