Lawan v. Moleta
REITERATIONFacts
The Antecedents: Complainant Sancho Lawan charged Municipal Judge Antonio P. Moleta with delayed judgment in Criminal Case No. 869 for oral defamation, failure to pay just debts, habitual drunkenness, and absenteeism and tardiness. Procedural History: Respondent Judge Moleta filed a comment denying the charges. He contended that the complainant was a disgruntled litigant whom he had sentenced in the oral defamation case. He provided explanations and evidence for each charge, including a receipt for alleged debts, a medical certificate for hypertension, and explanations for the delay in judgment related to stenographic transcription and his designation to another court. The Petition: The complainant filed a verified complaint detailing the charges against the respondent judge.
Issue(s)
Whether the respondent judge incurred delay in rendering judgment in Criminal Case No. 869. Whether the respondent judge failed to pay just debts. Whether the respondent judge was guilty of habitual drunkenness. Whether the respondent judge was guilty of absenteeism and tardiness.
Ruling
The charges of failure to pay just debts, habitual drunkenness, and absenteeism and tardiness were dismissed. However, the respondent judge was found guilty of delay in rendering judgment and was reprimanded and admonished.
Ratio Decidendi
On Delay in Judgment: The respondent judge admitted that he rendered the decision in Criminal Case No. 869 on May 23, 1977, which was 128 days after the case was submitted for decision. He argued that the 90-day period should be counted from March 1, 1977, the date his stenographer's transcript of stenographic notes was due, rather than from January 15, 1977, the date the parties' memoranda were due. This contention was found untenable. The Court clarified that the 90-day period for deciding a case commences from the date the case is submitted for decision, which occurs upon the termination of the trial or the expiration of the period to file memoranda. The Court emphasized that judges are directed to take notes during hearings and prepare decisions without waiting for the transcript of stenographic notes, citing Circular No. 87 of the Department of Justice and the ruling in In Re Impeachment of Flordeliza. Therefore, the respondent judge was guilty of delay as he decided the case 128 days after submission, exceeding the constitutional and statutory 90-day period. On Failure to Pay Just Debts: The charge was dismissed. The Court found that a receipt dated September 17, 1976, issued by Fresnida Lawan, wife of Sergio Lawan (complainant's brother), acknowledged payment by the respondent judge for all his vales and accounts with Lawans' store and carinderia. This receipt negated any claim of an outstanding account incurred prior to that date. On Habitual Drunkenness: The charge was deemed satisfactorily explained and dismissed. The respondent judge presented a certification from the Rural Health Physician stating he was under medical care for hypertension since 1975 and had been advised to refrain from drinking alcoholic beverages. The Court reasoned that a habitual drunkard would not likely survive with such a condition, and the complainant failed to present any witnesses to support the charge. On Absenteeism and Tardiness: This charge was dismissed for lack of proof. The complainant failed to present any evidence to substantiate the allegations of absenteeism and tardiness. Consequently, the presumption of regular performance of official duties by the respondent judge stood.
Main Doctrine
A judge is accountable for delay in rendering judgment if the 90-day period for decision is reckoned from the submission of the case, not from the completion of the transcript of stenographic notes. Judges are expected to take notes during hearings and proceed with decision preparation without awaiting transcripts.