Cruz v. Basa
REITERATIONFacts
The Antecedents: Complainant Atty. Cornelio C. Cruz charged respondent Judge Romulo C. Basa of the Municipal Trial Court (MTC) of Norzagaray, Bulacan, with serious misconduct. The charge stemmed from the alleged delay in the resolution of a motion to dismiss filed in twenty (20) estafa cases against Rodolfo Cruz, and the subsequent submission of a false Monthly Report to the Supreme Court indicating these cases had been disposed of. Procedural History: The accused in the estafa cases moved for their dismissal, arguing they should be prosecuted under the Rule on Summary Procedure. Complainant opposed, asserting the penalty imposable exceeded the limits for summary procedure. Respondent judge set the motion for oral argument on February 18, 1991, but failed to resolve the issue until June 3, 1991, prompting a motion for inhibition. Meanwhile, in May 1991, complainant discovered the respondent judge had reported the cases as disposed of in the April 30, 1991 Monthly Report, despite pending resolutions. The Petition: The administrative complaint was filed charging serious misconduct for delay in resolution and submitting a false report. The Office of the Court Administrator found the respondent judge guilty. The Supreme Court reviewed the case.
Issue(s)
Whether respondent judge committed serious misconduct by delaying the resolution of the motion to dismiss. Whether respondent judge committed serious misconduct by submitting a false Monthly Report to the Supreme Court.
Ruling
The Supreme Court found respondent Judge Romulo C. Basa guilty of serious misconduct. He was reprimanded for delaying the resolution of the motion to dismiss and fined P5,000.00 for submitting a false monthly report, with a warning that similar offenses in the future would be dealt with more severely.
Ratio Decidendi
On the issue of delaying the resolution of the motion to dismiss: The Court found that respondent judge failed to resolve the motion to dismiss, which involved a simple issue, for an unreasonable period of over three months (from February 18, 1991, to June 3, 1991). The Court rejected the respondent's explanation that a draft resolution was prepared but not signed due to the motion for inhibition, noting the inhibition motion was filed after the period for resolution had already passed. This inaction was deemed a violation of Canon 3, Rule 3.05 of the Code of Judicial Conduct, which mandates judges to dispose of court business promptly and decide cases within the required periods. The Court emphasized that delay in resolving pending incidents is inexcusable and cannot be countenanced, as it gives room for suspicion and erodes faith in the administration of justice. On the issue of submitting a false monthly report: The Court found the respondent judge liable for submitting or causing the submission of a false Monthly Report to the Statistics Division of the Supreme Court. Reporting the cases as "disposed" when they were still pending resolution was considered a serious offense. The respondent's explanation that an unsigned draft resolution existed was deemed insufficient to justify the false report. The Court stressed that if a judge's caseload prevented timely disposition, the proper recourse was to request an extension of time from the Supreme Court, not to submit inaccurate reports. The Court stated that the submission of a false report cannot be casually disregarded and constitutes serious misconduct.
Main Doctrine
A judge who delays the resolution of a motion to dismiss and submits a false monthly report to the Supreme Court is guilty of serious misconduct. Such delay violates the Code of Judicial Conduct, and submitting false reports cannot be countenanced, even if an unsigned draft resolution exists.