G.R. No. RTJ-12-2325 April 14, 2015
OFFICE OF THE COURT ADMINISTRATOR, Complainant, vs. JUDGE ALAN L. FLORES, PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH 7, TUBOD, LANAO DEL NORTE AND FORMER ACTING PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH 21, KAPATAGAN, LANAO DEL NORTE, Respondent. (Consolidated with A.M. OCA IPI No. 11-3649-RTJ: PROSECUTOR DIOSDADO D. CABRERA, Complainant, vs. JUDGE ALAN L. FLORES, PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH 7, TUBOD, LANAO DEL NORTE AND FORMER ACTING PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH 21, KAPATAGAN, LANAO DEL NORTE, Respondent.)

FACTS

This case involves two consolidated administrative complaints against Judge Alan L. Flores. The first, A.M. No. RTJ-12-2325, originated from an OCA investigation prompted by two anonymous letters (from “John Hancock” and “Concerned Citizens”) accusing Judge Flores of: rendering favorable judgments for monetary consideration; taking cognizance of and deciding annulment cases beyond his court’s territorial jurisdiction; and improperly entertaining OCA audit teams. Specific allegations included demanding ₱5,000 for special proceedings, maintaining non-court personnel as errand boys and security, engaging in drinking sprees, and claiming protection from a Supreme Court Justice.
Acting on these, the OCA conducted an audit and investigation of cases in RTC Branch 7, Tubod, and RTC Branch 21, Kapatagan, both presided by Judge Flores. The OCA Report found multiple irregularities: 1) In numerous active and decided petitions for declaration of nullity of marriage (e.g., Salvador v. Salvador, Amba v. Amba, Neri v. Neri, Dabuet v. Dabuet, Jr., Maybituin v. Dayanan-Maybituin, and others like Benitez, Narvasa, Emborong, Cangcolcol, Mancia), Judge Flores disregarded A.M. No. 02-11-10-SC (Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages) by ignoring clear violations of the residency/venue rule, such as petitioners using “care of” addresses, providing non-existent addresses, or lacking the requisite six-month residency. 2) He decided these cases with undue haste, within periods ranging from 6 months to 1 year and 7 months from filing. 3) In Gallibot v. Gallibot, a petition for judicial declaration of presumptive death, he granted the petition despite the petitioner’s address being non-existent. 4) In multiple criminal cases (People v. Pinuti, Jr.; People v. Rivera, et al.; People v. Gomera and Alfafara; People v. Mautin, et al.; People v. Pasanting; People v. Guigue and Clerigo), he resolved motions (e.g., motions to dismiss, demurrers to evidence, motions for reconsideration) beyond the reglementary period, with delays ranging from 7 months to over 1 year and 6 months, or left them pending beyond the period.
The second case, A.M. OCA IPI No. 11-3649-RTJ, was filed by Prosecutor Diosdado D. Cabrera. He alleged that in Placibe v. Placibe, Judge Flores set aside his (Prosecutor Cabrera’s) investigation report which recommended dismissal due to lack of jurisdiction (both parties were residents of Misamis Oriental, not Lanao del Norte). Judge Flores incorrectly asserted that the prosecutor’s role was limited to determining collusion, not jurisdiction. Prosecutor Cabrera also accused Judge Flores of berating and insulting him in open court.
In his defense, Judge Flores denied all allegations of corruption and impropriety. He claimed the anonymous complaints were orchestrated by a disgruntled lawyer. Regarding the annulment cases, he argued he exercised judicial discretion in determining residency based on the petitioners’ allegations and testimonies, and that any errors were judicial in nature, not administrative. For the delays in criminal cases, he cited heavy workload and claimed some delays were attributable to the court staff or the parties. He denied berating Prosecutor Cabrera.
The OCA, in its evaluation, found Judge Flores guilty of gross ignorance of the law/procedure and undue delay in rendering decisions/orders. It recommended a fine of ₱40,000 for gross ignorance and ₱20,000 for undue delay, with a stern warning.

ISSUE

Whether Judge Alan L. Flores is administratively liable for the acts complained of, and if so, what is the appropriate penalty.

RULING

Yes, Judge Alan L. Flores is administratively liable. The Court found him guilty of Gross Ignorance of the Law and Undue Delay in Rendering Decisions and Orders.
The Court emphasized that judges must be proficient in the law. Judge Flores’ blatant disregard of the clear residency requirements under A.M. No. 02-11-10-SC constituted gross ignorance of the law. The rule mandates that the petition must be filed in the Family Court of the province or city where the petitioner or respondent has been residing for at least six months prior to filing. The OCA audit revealed multiple cases where petitioners used “care of” addresses, provided non-existent addresses (e.g., “Barangay Bag-ong Dawis” in Tubod which does not exist), or lacked the six-month residency. By taking cognizance of and deciding these cases, Judge Flores exhibited a gross lack of familiarity with a basic and mandatory rule, which is inexcusable. His defense of exercising judicial discretion was rejected, as the facts plainly showed absence of jurisdiction.
Furthermore, his undue haste in deciding these void petitions (within 6 months to 1 year and 7 months) compounded the irregularity, suggesting a priority to dispose of such cases quickly, potentially for improper motives hinted at in the anonymous letters.
Regarding the criminal cases, the Court found Judge Flores guilty of undue delay. The Constitution and rules mandate that judges resolve cases and matters within specified periods. Delays of several months to over a year in resolving motions, as documented, are indefensible. His plea of heavy workload was insufficient, as managing the court’s docket is his responsibility.
While the charges of corruption and immorality from the anonymous letters were not substantiated by convincing evidence, the procedural violations established from the OCA’s record-based audit were more than sufficient to warrant administrative sanction.
The Court modified the OCA’s recommended penalty. For Gross Ignorance of the Law, a more severe penalty was imposed due to the gravity and repetition of the offense. For Undue Delay, the recommended fine was sustained. Judge Flores was FINED ₱100,000.00 for Gross Ignorance of the Law and ₱20,000.00 for Undue Delay in Rendering Decisions and Orders, with a STERN WARNING that a repetition of similar acts would be dealt with more severely.