G.R. No. RTJ-10-2244. November 28, 2012. OFFICE OF THE COURT ADMINISTRATOR, Complainant, vs. JUDGE LYLIHA A. AQUINO, Regional Trial Court, Branch 4, Tuguegarao City, Cagayan, Respondent.
FACTS

The Office of the Court Administrator (OCA) conducted a judicial audit of respondent Judge Lyliha A. Aquino’s court following an anonymous complaint alleging corruption and other malpractices. The audit focused on her handling of annulment/nullity of marriage and adoption cases. It was discovered that from June 2003 to January 2009, Judge Aquino decided forty-one family law cases without strictly complying with mandatory procedural safeguards. Specifically, she proceeded with hearings and decisions without the required no-collusion investigation report from the public prosecutor and without conducting pre-trial conferences as mandated by the Rule on Declaration of Nullity of Void Marriages and Annulment of Voidable Marriages. In adoption cases, she decided twenty-six petitions despite lacking essential documents like child study reports, affidavits of consent, and home study reports, as required by the Rule on Adoption.
In her Comment, Judge Aquino denied the corruption allegations. Regarding the procedural lapses, she argued that ordering a collusion investigation was within her discretion and that the necessity of certain adoption documents depended on case circumstances. She admitted to proceeding with hearings even in the absence of the prosecutor’s report, characterizing this as an exercise of judicial discretion to expedite case resolution.

ISSUE

Whether Judge Aquino is administratively liable for her failure to comply with mandatory procedural rules in annulment and adoption cases.

RULING

Yes, Judge Aquino is administratively liable. The Court agreed with the OCA’s findings that the judge violated specific rules. In annulment cases, the prosecutor’s investigation report is a condition sine qua non for pre-trial; it is not discretionary. Its purpose is to ensure the absence of collusion, a fundamental safeguard in these sensitive proceedings. Similarly, the documents required in adoption cases are not optional but are jurisdictional prerequisites designed to protect the welfare of the child. The Court emphasized that judges cannot take shortcuts or disregard procedural rules solely to achieve speed, as the integrity of the judicial process is paramount.
While the Court found no evidence of bad faith or malice, and no harm to litigants was demonstrated, the infractions constituted gross ignorance of the law or procedure. A judge’s duty to be thoroughly acquainted with the laws and rules is mandatory. Her admission of proceeding without required reports confirmed the violation. Consequently, the Court imposed a fine of Ten Thousand Pesos (P10,000.00) with a stern warning that a repetition would be dealt with more severely. The matter of the corruption allegations was referred back to the OCA for a separate investigation.