A.M. No. RTJ-16-2463. August 30, 2022.
Office of the Court Administrator, complainant, vs. Judge Candelario V. Gonzales, Regional Trial Court, Branch 45, Bais City.

FACTS

This administrative case originated from a 2015 judicial audit of RTC Branch 45 in Bais City, presided by Judge Candelario V. Gonzales. The audit revealed a massive caseload of 962 active cases. Critically, Judge Gonzales had failed to decide 211 cases and resolve pending incidents in 71 others within the reglementary period. Furthermore, he did not request extensions for these delays and, most egregiously, failed to report these pending cases in his Certificates of Service and Docket Inventory for 2013 and 2014, making untruthful declarations. The Office of the Court Administrator (OCA) directed him to explain these deficiencies. In his defense, Judge Gonzales cited health issues, including an angioplasty in 2013, and staffing problems. He also claimed to have subsequently decided almost all backlogged cases.
In a Decision dated July 27, 2021, the Court found Judge Gonzales guilty of Gross Misconduct, Delay in Rendering Decisions, and Making Untruthful Statements in his Certificates of Service. He was dismissed from service with forfeiture of benefits and ordered to pay fines. Judge Gonzales filed a Motion for Reconsideration, pleading for humanitarian consideration, citing his medical condition, his efforts to clear the docket, and his over 40 years of government service prior to his 2021 retirement.

ISSUE

Whether the penalty of dismissal from service imposed on Judge Gonzales should be modified upon reconsideration.

RULING

Yes, the penalty is modified. The Court partially granted the Motion for Reconsideration. While the findings of administrative liability stand, the Court reassessed the penalty in light of mitigating factors. The Court acknowledged the gravity of the offenses, particularly the falsification of monthly reports which constitutes serious dishonesty. However, it considered significant mitigating circumstances: Judge Gonzales had no prior record involving corruption or moral turpitude; his long government service of over 40 years was largely unblemished aside from a prior warning for a different offense; his serious health condition contributed to the delay; and he had demonstrated effort to rectify the backlog before retirement.
Applying the guidelines under the amended Rule 140 of the Rules of Court, which allow for the consideration of mitigating and aggravating circumstances, the Court found that the mitigating factors outweighed the aggravating ones. Since Judge Gonzales had already retired, dismissal was no longer feasible. Consequently, the Court substituted the penalty with a fine of P400,000.00, to be deducted from his retirement benefits. This fine answers for the consolidated infractions of gross misconduct (for the false reports), undue delay, and untruthful statements. The Court also lifted his disqualification from future government employment.