Surigao Citizens' Movement v. Coro
A.M. No. MTJ-96-1099 (September 23, 1996)
Facts:
On March 22, 1995, the Surigao Citizens' Movement for Good Government (SURCIMO), represented by its Chairman Eduardo S. Barotac, filed a letter-complaint against Judge Flordeliza D. Coro of the Municipal Circuit Trial Court (MCTC) of Del Carmen-San Benito-San Isidro, Surigao del Norte. The complaint alleged that Judge Coro exhibited undue delay in the disposition of cases and engaged in the indiscriminate archiving of cases. The letter included a list of cases that had allegedly remained unresolved for several years in Judge Coro's sala, some of which were outside the jurisdiction of the MCTC.
In response to the complaint, Executive Judge Melchor Libarnes directed Judge Coro to comment within ten days. However, she failed to comply with this directive, prompting Judge Libarnes to extend the deadline. After Judge Coro still did not respond, the complaint was forwarded to the Office of the Court Administrator on July 24, 1995.
On October 18, 1995, the Supreme Court required Judge Coro to file her comment and ordered Judge Libarnes to conduct an audit and inventory of the cases pending in her sala. Judge Libarnes submitted his report on January 29, 1996, which included Judge Coro's comment and a tabulated report on the status of the cases. Judge Libarnes noted that the criminal cases specified in the complaint had been given preference and resolved expeditiously by Judge Coro.
Judge Coro denied the allegations, asserting that she acted on all cases except those where the accused were at large, which she archived to clean the court's docket. However, she admitted that she was instructed to forward cases outside her jurisdiction to the Provincial Prosecutor.
The records indicated that as of March 31, 1995, there were at least thirty-five archived cases in Judge Coro's sala, nineteen of which were not within the MCTC's jurisdiction. Instead of forwarding these cases, Judge Coro archived them, claiming the accused had not been arrested. This action was found to violate the procedural rules regarding preliminary investigations.
Further examination revealed that Judge Coro had only acted on these cases after the complaint was filed, indicating negligence in her duties. This was not her first offense, as she had previously been found guilty of releasing prisoners without bail.
Legal Issues:
- Whether Judge Flordeliza D. Coro was guilty of gross inefficiency and negligence in the handling of cases in her sala.
- Whether her actions constituted a violation of the procedural rules regarding the archiving and resolution of cases.
Arguments:
Complainant's Argument: SURCIMO argued that Judge Coro's failure to resolve cases in a timely manner and her indiscriminate archiving of cases constituted gross inefficiency and negligence. They highlighted the significant delays in the resolution of cases, some pending for several years, and the improper archiving of cases outside her jurisdiction.
Respondent's Argument: Judge Coro contended that she acted on all cases except those involving accused persons who were at large. She claimed that archiving was a necessary measure to manage the court's docket and that she had issued resolutions forwarding cases to the Provincial Prosecutor, albeit belatedly.
Court's Decision and Legal Reasoning:
The Supreme Court found Judge Coro guilty of gross inefficiency and negligence. The Court noted that the records showed a significant number of archived cases, many of which were outside her jurisdiction. The Court emphasized that her failure to act on these cases for years constituted a clear violation of the rules requiring prompt resolution of cases, particularly those requiring preliminary investigations.
The Court also pointed out that Judge Coro's actions were not only negligent but also indicative of a lack of diligence in her duties as a presiding judge. The fact that she only reviewed the archived cases after the complaint was filed demonstrated a failure to uphold her responsibilities.
Given that this was Judge Coro's second offense, the Court imposed the penalty of dismissal from service, forfeiting all leave credits and retirement benefits, and disqualifying her from reemployment in any government position.
Significant Legal Principles Established:
- Judges have a duty to resolve cases promptly and efficiently, adhering to procedural rules regarding preliminary investigations and case management.
- Indiscriminate archiving of cases, especially those outside a judge's jurisdiction, constitutes gross negligence and inefficiency.
- Repeat offenses by judges can lead to severe penalties, including dismissal from service.