AM RTJ 17 2507; (October, 2017) (Digest)
G.R. No. A.M. No. RTJ-17-2507. October 9, 2017.
Re: Anonymous Complaints against Hon. Dinah Evangeline B. Bandong, former Presiding Judge, Regional Trial Court, Branch 59, Lucena City, Quezon Province.
FACTS
The Office of the Court Administrator (OCA) received multiple anonymous complaints against then Presiding Judge Dinah Evangeline B. Bandong. The complaints alleged gross inefficiency and misconduct, including her failure to study case records, instead delegating the task of digesting or narrating cases to her staff, which caused a backlog in stenographic notes. She was accused of compelling parties to settle even in non-mediatable criminal cases like rape, which was already submitted for decision prior to her assumption, and of repeatedly postponing hearings to force settlements. Complainants also stated she would call court recesses to watch television in her chambers. Further, she was alleged to have tolerated the misconduct of a staff member, Eduardo Febrer, who was accused of demanding money from litigants for case follow-ups.
An investigation was conducted by the Executive Judge of RTC Lucena City, who corroborated many allegations. The Executive Judge confirmed Judge Bandong’s practice of pushing for settlements in criminal cases, her admission in open court of an inability to resolve cases, and her failure to conduct hearings, making her sala a subject of ridicule. Judge Bandong had already been approved for optional retirement, but the release of her benefits was withheld pending the resolution of these and other administrative complaints.
ISSUE
Whether Judge Bandong is administratively liable for Gross Ignorance of the Law, Gross Misconduct, and Inefficiency based on the anonymous complaints and the investigative report.
RULING
Yes, Judge Bandong is administratively liable. The Court found the complaints substantiated by the Executive Judge’s detailed report, which carried great weight as it came from a fellow judge tasked with court supervision. Judge Bandong’s actions constituted Gross Ignorance of the Law and Gross Misconduct. Her persistent and unwarranted push for amicable settlements, particularly in a criminal case for rape—a heinous crime not subject to compromise—demonstrated a fundamental disregard for substantive law and procedure. This act alone prejudiced the pursuit of justice. Her abdication of judicial duty by having staff members digest cases and her admissions in court of an inability to understand or decide cases revealed incompetence and neglect, contributing to inefficiency and delay. Furthermore, her conduct of watching television during court hours and calling recesses for this purpose constituted gross misconduct, being conduct unbecoming of a magistrate that eroded public confidence in the judiciary. While the complaints were anonymous, the Court ruled that the gravity of the charges, coupled with the official corroboration from the Executive Judge, warranted action. The fact of her retirement did not preclude administrative liability. For these infractions, the Court imposed a fine of P40,000, to be deducted from her withheld retirement benefits, with a stern warning that a repetition of similar acts would be dealt with more severely.
