G.R. No. RTJ-94-1208. January 26, 1995. JACINTO MAPPALA, complainant, vs. JUDGE CRISPULO A. NUÑEZ, Regional Trial Court, Branch 22, Cabagan, Isabela, respondent.
FACTS

Complainant Jacinto Mappala, the victim and private complainant in a frustrated murder case, filed an administrative complaint against Judge Crispulo A. Nuñez for gross inefficiency, serious misconduct, and violation of the Code of Judicial Ethics. The charges stemmed from the judge’s handling of three consolidated criminal cases where Alejandro Angoluan was a principal accused. The cases were submitted for decision on May 27, 1993, following the filing of the last pleading. However, Judge Nuñez rendered his consolidated decision only on December 20, 1993, which was seven months later.
The complainant specifically alleged gross inefficiency due to the delay in decision-making. He also charged serious misconduct, arguing that the judge erroneously acquitted Alejandro Angoluan of a violation of the Omnibus Election Code (for carrying a firearm within a polling place) despite factual findings that established the offense. An additional charge of violating judicial ethics was based on the judge’s alleged credence to an uncorroborated alibi. The complainant further accused the judge of accepting bribes, though this was not substantiated.

ISSUE

Whether respondent Judge Crispulo A. Nuñez is administratively liable for gross inefficiency and serious misconduct in relation to his delay in rendering judgment and his decision to acquit an accused of an election offense.

RULING

Yes, the respondent judge is administratively liable for gross inefficiency but not for serious misconduct regarding his judicial discretion. On the charge of gross inefficiency, the Court found the judge guilty. The 90-day reglementary period for deciding cases, mandated by the Constitution and the Judiciary Act, is mandatory. The period commenced on May 27, 1993, when the last pleading was submitted, yet the decision was promulgated seven months later on December 20, 1993. The judge’s justification—that the consolidated cases involving grave offenses required more time—was unacceptable. The proper recourse was to request an extension from the Supreme Court, which he failed to do. This undue delay constitutes gross inefficiency warranting administrative sanction.
Regarding the charge of serious misconduct for acquitting Alejandro Angoluan of the election offense, the Court held the judge not liable. While the Court found the acquittal legally erroneous based on the judge’s own factual findings—that the accused shot the complainant inside the precinct during the election—the error pertained to an exercise of judicial discretion and interpretation of law. An administrative complaint is not the proper remedy to correct such judicial errors, which should be raised on appeal. The charge of accepting bribes was dismissed for lack of substantiation. Consequently, the Court imposed a fine of Five Thousand Pesos (P5,000.00) on Judge Nuñez for gross inefficiency, with a stern warning against repetition.