Hernandez v. De Guzman

A.M. No. RTJ-93-1064 (January 22, 1996)

Facts:

Emilia B. Hernandez filed a letter-complaint on August 9, 1993, against Judge Salvador P. de Guzman of the Regional Trial Court, Branch 142, Makati City, alleging bias and undue delay in the resolution of her case. Hernandez was the complainant in Criminal Case No. 89-1198, which involved the prosecution of Yadollah Sichani for illegal recruitment under Article 34(i) of P.D. 442, as amended. The trial lasted for approximately four years, during which Hernandez expressed dissatisfaction with the process, claiming that the judge's actions prolonged the case unnecessarily and that the indemnity awarded to her was insufficient.

On February 23, 1993, Judge de Guzman rendered a judgment convicting Sichani, imposing a fine of P5,000.00 and ordering him to indemnify Hernandez in the same amount. Hernandez contended that the judge's delay in the trial and the amount of indemnity were indicative of bias against her.

In his defense, Judge de Guzman argued that the delays were primarily due to Hernandez's own actions, as she had requested multiple postponements to secure the testimony of witnesses. He claimed that after the case was submitted for resolution on May 28, 1992, he prepared the decision promptly, but the promulgation was delayed due to Hernandez's insistence on reopening the case for additional witnesses. Furthermore, he pointed out that the indemnity amount was based on the findings of the Philippine Overseas Employment Administration (POEA), which determined her damages to be only P3,000.00.

The complaint was referred to the Court Administrator for evaluation, and after a thorough review, the case was forwarded to the Supreme Court for disposition.

Legal Issues:

1. Was there undue delay in the trial and resolution of Criminal Case No. 89-1198?
2. Did the respondent judge exhibit bias in the award of indemnity to the complainant?
3. Is an administrative complaint the appropriate forum for questioning the propriety of a judicial decision?

Arguments:

Complainant's Arguments:

• Hernandez argued that the judge's repeated resetting of hearings led to an unreasonable delay of four years in the trial.
• She claimed that the P5,000.00 indemnity was inadequate and a result of the judge's bias against her.

Respondent's Arguments:

• Judge de Guzman contended that the delays were largely due to Hernandez's requests for postponements and her attempts to secure witness testimonies.
• He maintained that the indemnity amount was justified based on the POEA's findings, which indicated her actual damages were only P3,000.00.
• The judge also pointed out that Hernandez's complaint was not sworn, which is a requirement under Rule 140 of the Revised Rules of Court.

Court's Decision and Legal Reasoning:

The Supreme Court found merit in the complaint regarding the undue delay in the trial. While acknowledging that some delays were attributable to Hernandez, the Court emphasized that Judge de Guzman should have exercised stricter control over the proceedings and adhered to the guidelines set forth in Circular No. 1, which mandates trial judges to avoid unnecessary postponements. The Court noted that the case was deemed submitted for decision on May 28, 1992, and should have been resolved by August 1992. The delay in promulgating the judgment, which was dated February 23, 1993, was deemed excessive.

Regarding the indemnity, the Court ruled that the matter was judicial in nature and that Hernandez had other legal remedies available to contest the award. The Court clarified that an administrative complaint is not the proper venue for challenging the merits of a judicial decision.

The Court imposed a fine of P5,000.00 on Judge de Guzman for the delay and issued a stern warning against future similar conduct.

Significant Legal Principles Established:

• Judges must maintain strict control over court proceedings and adhere to timelines for the resolution of cases to prevent undue delays.
• Administrative complaints against judges are not the appropriate forum for questioning the merits of judicial decisions; such matters should be addressed through the proper legal channels.
• The requirement for complaints against judges to be sworn is emphasized to ensure the integrity of the complaint process.