AM RTJ 20 2584; (July, 2020) (Digest)
G.R. No. A.M. No. RTJ-20-2584 (formerly OCA IPI No. 18-4841-RTJ). July 28, 2020.
Hortencia R. Cayabyab, complainant, vs. Presiding Judge Irineo P. Pangilinan, Jr., Regional Trial Court, Branch 58, Angeles City, Pampanga, respondent.
FACTS
Complainant Hortencia R. Cayabyab was the private complainant in Criminal Case No. 10-5530 for Perjury against her adopted daughter, filed before the court of respondent Judge Irineo P. Pangilinan, Jr., then Presiding Judge of the Municipal Trial Court in Cities of Angeles City, Branch 1. The case alleged the accused knowingly executed a false Affidavit of Loss regarding an owner’s duplicate certificate of title. The promulgation of judgment, originally set for July 28, 2016, was reset thrice without a request for extension. Judge Pangilinan rendered a decision acquitting the accused on October 20, 2016, or four months after the case was submitted for decision on June 16, 2016. In his decision, Judge Pangilinan found the accused deliberately executed the false affidavit but acquitted her due to an absence of malice or evil intent, reasoning she was the registered owner and could sell the property. This decision was later reversed and set aside by the RTC, Branch 56, for grave abuse of discretion. Cayabyab filed this administrative complaint alleging undue delay in rendering a decision, knowingly rendering an unjust judgment, and gross ignorance of the law. She also relayed information that the accused and Judge Pangilinan belonged to the same church and that a pastor interceded on the accused’s behalf. Judge Pangilinan denied the allegations, claiming the complaint was harassment, that the original promulgation date was within the 90-day period, and that he sought to reconcile the parties due to their familial relationship.
ISSUE
Whether Judge Pangilinan should be administratively held liable for undue delay in rendering a decision, knowingly rendering an unjust judgment, and gross ignorance of the law.
RULING
The Court found Judge Pangilinan administratively liable for UNDUE DELAY IN RENDERING A DECISION but dismissed the charges for knowingly rendering an unjust judgment and gross ignorance of the law.
1. On Undue Delay: Judge Pangilinan incurred undue delay. The Constitution and the New Code of Judicial Conduct require lower courts to decide cases within three months from submission. Criminal Case No. 10-5530 was decided four months after submission on June 16, 2016. His justification—desiring an amicable settlement between the parties in a perjury case that had concluded trial—was unreasonable. Furthermore, he failed to request an extension from the Court, which is mandatory if unable to comply with the reglementary period. Undue delay is a less serious charge under Rule 140. Considering this was his first offense for undue delay but noting a prior reprimand in a separate case for gross ignorance of the law, the Court imposed a fine of P10,000.00, modifying the OCA’s recommended penalty of reprimand.
2. On Knowingly Rendering an Unjust Judgment: The charge was dismissed. Knowingly rendering an unjust judgment under Article 204 of the Revised Penal Code requires proof beyond reasonable doubt that the judgment was not only contrary to law or evidence but rendered with a conscious and deliberate intent to do an injustice (bad faith, hatred, revenge, etc.). The error attributed to Judge Pangilinan, even if his decision was later reversed, constituted at most an error of judgment. The complainant failed to prove bad faith or a corrupt motive. Allegations of church affiliation and intercession were unsubstantiated.
3. On Gross Ignorance of the Law: The charge was dismissed. Gross ignorance of the law implies a gross disregard of basic rules or settled jurisprudence. For liability to attach, the error must be gross or patent, deliberate, and malicious. A judge’s legal error, absent fraud, dishonesty, or deliberate intent to commit an injustice, is not necessarily administratively liable. The mistake in Judge Pangilinan’s acquittal rationale, while potentially a misapplication of law, did not rise to the level of gross ignorance constitutive of bad faith. The proper remedy for judicial errors is judicial review, not administrative sanction.
DISPOSITIVE PORTION: Judge Pangilinan was FINED Ten Thousand Pesos (P10,000.00) for undue delay in rendering a decision, with a stern warning that a repetition of the same or similar act shall be dealt with more severely. The other charges were dismissed for lack of merit.
