G.R. No.: A.M. No. RTJ-21-2606 (formerly A.M. No. 20-12-164-RTC). February 9, 2021.
Case Parties: Office of the Court Administrator, complainant, versus Judge Victor Teves, Sr., Former Presiding Judge, and Tito Valencia, Process Server, Regional Trial Court (RTC)-Branch 54, Lapu-Lapu City, Cebu, respondents.

FACTS

This administrative case originated from two judicial audits conducted at RTC-Branch 54 in Lapu-Lapu City, Cebu, then presided by Judge Victor Teves, Sr. The first audit was from February 22 to March 3, 2016. A second audit was conducted on November 18-19, 2019, after Judge Teves filed for optional retirement.
The first audit revealed multiple procedural lapses. The Office of the Court Administrator (OCA) issued several memoranda directing Judge Teves to: 1) act on dormant cases and cases with pending motions; 2) explain delays in resolving motions and deciding cases; 3) explain why 44 annulment/nullity of marriage cases were heard and decided without required attachments; 4) forward proof of arraignment in specific criminal cases; and 5) investigate reports of a court “sinking fund” from marriage solemnization donations.
Judge Teves attributed delays to an increased caseload, the full-time designation of his Clerk of Court, the failure of his Legal Researcher, and the retirement of a clerk. He apologized and claimed to have acted on most cases. Regarding the annulment cases, he pointed to possible audit errors and reliance on the regularity of his staff’s duties, while admitting some infractions. On the “sinking fund,” he issued a memorandum prohibiting donations.
The OCA found his explanations unsatisfactory and directed him to explain why he should not be charged with gross dereliction of duty, gross inefficiency, and gross incompetence for non-compliance.
Separately, Process Server Tito Valencia was directed to explain why he immediately resorted to substituted service of summons in several annulment cases, including one where summons was served in Parañaque City. Valencia cited voluminous work and additional duties, admitted his lapses, and asked for leniency. He failed to submit proof of his travel to Parañaque or proper authorization for the out-of-jurisdiction service despite subsequent OCA directives.
The second audit found a total caseload of 714 cases. While Judge Teves had acted on cases flagged by auditors, the OCA noted unattached pleadings, a lapse attributed to the clerical staff, not the judge.

ISSUE

Whether respondents Judge Victor Teves, Sr. and Tito Valencia are administratively liable for the infractions uncovered during the judicial audits.

RULING

Yes, both respondents are administratively liable.
1. As to Judge Victor Teves, Sr.: The Court found him guilty of Gross Inefficiency and Gross Incompetence for his failure to decide cases and resolve motions within the reglementary period. His excuses of heavy caseload and staff issues were deemed unacceptable, as judges are primarily responsible for managing their courts and ensuring prompt case disposition. His failure to comply with the OCA’s repeated directives compounded his liability. Since he had already retired, the Court imposed a FINE equivalent to his basic salary for six (6) months, to be deducted from his retirement benefits.
2. As to Tito Valencia: The Court found him guilty of Simple Neglect of Duty for his failure to abide by the rules on service of summons. He improperly resorted to substituted service without attempting personal service and served summons outside the court’s territorial jurisdiction without authorization or proof. Considering his long service with no prior administrative record, the Court imposed a FINE of Twenty Thousand Pesos (P20,000.00) with a STERN WARNING that a repetition would warrant a more severe penalty.
The two judicial audit reports were re-docketed as a regular administrative complaint, and the OCA’s recommendations were adopted.