CASE DIGEST
JOSELITO R. ENRIQUEZ, complainant, vs. JUDGE PLACIDO B. VALLARTA, Municipal Circuit Trial Court (MCTC), Cabiao- San Isidro, Nueva Ecija,respondent.
FACTS:
This is a complaint against Judge Placido B. Vallarta, Presiding Judge of the Municipal Circuit Trial Court (MCTC), Cabiao-San Isidro, Nueva Ecija, for falsification of certificates of service, gross ignorance of the law, and grave abuse of authority and discretion, in connection with his handling of Criminal Case. Respondent judge ordered the parties to submit memoranda, which is prohibited under §19(f) of the Revised Rule on Summary Procedure. Respondent judge subsequently found complainant’s client guilty of the crime charged and sentenced him to 25 days of imprisonment without costs. The trial was terminated on January 17, 2000, per the order of respondent judge himself. However, respondent’s decision was promulgated only on September 26, 2000.
In his comment, as for his order
requiring the parties to submit their memoranda, respondent judge says that
what he actually meant was for them to submit a “position
paper.” Respondent judge explained that such lapse was due to the
fact that he had so many things to do, having been assigned to three courts and
holding daily hearings. Finally, he maintains that the
decision, dated April 27, 2000, was rendered within 30 days counted from
the order, dated March 28, 2000, as provided in the Revised Rule on
Summary Procedure.
ISSUE: Whether or not the
respondent judge is guilty of gross ignorance of the law.
HELD: YES. By directing the
filing of memoranda in the criminal case, respondent judge evidently was
unaware that a requirement to submit a memorandum is prohibited in a summary
proceeding. Consequently, respondent judge’s excuse that what he meant was
a “position paper” and not a memorandum is even more revealing of his
unawareness of the applicable rules.
That respondent judge had a heavy
caseload cannot justify his failure to observe a provision that particularly
applies to him. The Code of Judicial Conduct pertinently provides:
Rule 3.01. – A judge shall be faithful to the law and maintain professional competence. (emphasis supplied)
Canon 18 of the Code of Judicial
Ethics is equally clear:
Canon 18. INFLUENCE OF DECISIONS UPON THE DEVELOPMENT OF THE LAW
A judge should be mindful that his duty is the application of general law to particular instances, that ours is a government of laws and not of men, and that he violates his duty as a minister of justice under such a system if he seeks to do what he may personally consider substantial justice in a particular case and disregards the general law as he knows it to be binding on him. Such action may become a precedent unsettling accepted principles and may have detrimental consequences beyond the immediate controversy. He should administer his office with a due regard to the integrity of the system of the law itself, remembering that he is not a depository of arbitrary power, but a judge under the sanction of law. (emphasis supplied)
Respondent’s failure to decide the case on time constitutes a violation of Canon 3, Rule 3.05 of the Code of Judicial Conduct, which enjoins judges to dispose of their business promptly and decide cases within the required period. The need to decide cases promptly and expeditiously cannot be overemphasized, for justice delayed is justice denied. Delay in the disposition of cases undermines the people’s faith and confidence in the judiciary. Hence, the failure of judges to render judgment within the required period constitutes gross inefficiency, warranting the imposition of administrative sanctions on them.
WHEREFORE, Judge Placido B.
Vallarta is found guilty of ignorance of the law and delay in the disposition
of cases and is hereby ordered to pay a fine of P2,000.00, with admonition
to be more conscientious and prompt in the performance of his duties and with
warning that repetition of similar infractions will be sanctioned more
severely.
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