Hernandez v. De Guzman
REITERATIONFacts
The Antecedents: Emilia B. Hernandez filed a letter-complaint dated August 9, 1993, against Judge Salvador P. de Guzman of the Regional Trial Court (Branch 142), Makati City, for alleged bias. The complainant asserted that the judge deliberately delayed the trial of Criminal Case No. 89-1198, entitled "People vs. Yadollah Sichani," for violation of Art. 34(i) of P.D. 442, as amended (illegal recruitment), causing the proceedings to extend for four years and limiting her recovery to P5,000.00. Procedural History: After trial, respondent Judge rendered a judgment of conviction on February 23, 1993, sentencing the accused to pay a fine of P5,000.00 with subsidiary imprisonment and to indemnify Emilia Hernandez in the sum of P5,000.00. The complainant remained unsatisfied, claiming deliberate delay and bias in the indemnity awarded. The Petition: The complainant charged the respondent judge with bias for allegedly delaying the trial and awarding an unfair indemnity. The respondent judge, in his comment, attributed the delay to the complainant herself, stating she was given seven dates to present her witnesses. He also argued that the P5,000.00 indemnity was based on the complainant's own testimony of damages and an order from the POEA awarding only P3,000.00. Furthermore, he pointed out that the complaint was not under oath, contrary to Rule 140 of the Revised Rules of Court.
Issue(s)
Whether the respondent judge committed bias and deliberately delayed the trial of Criminal Case No. 89-1198. Whether the award of P5,000.00 as indemnity to the complainant was a result of bias. Whether the administrative complaint was the proper remedy for the complainant's grievances regarding the judicial decision.
Ruling
The Supreme Court imposed a fine of P5,000.00 on the respondent judge for the delay in hearing and deciding Criminal Case No. 89-1198, with a stern warning against repetition. The Court found the charge of undue delay meritorious, noting that even if the delay was partly attributable to the complainant, the judge should not have allowed frequent postponements and should have adhered to the time limits for decision-making. The Court also stated that an administrative complaint is not the proper forum to question the propriety of a judicial decision or order.
Ratio Decidendi
On the issue of bias and delay in trial: The Court found the charge of undue delay to be meritorious. While the respondent judge claimed the delay was attributable to the complainant's failure to present witnesses, the Court emphasized that judges must maintain control over their proceedings and adopt a strict policy against postponements, as mandated by Circular No. 1 dated January 28, 1988, and Rule 22 of the Rules of Court. The case was deemed submitted for resolution on May 28, 1992, and should have been decided by August 1992. The delay in rendering the judgment, dated February 23, 1993, and its subsequent promulgation, was deemed inexcusable, especially since it was based on hearsay information about the complainant wanting to reopen the case. The Court reiterated that judges must follow the time limits set for deciding cases and should not delay the preparation and promulgation of judgments on flimsy grounds. On the issue of the P5,000.00 indemnity award: The Court ruled that the matter of granting indemnity is judicial in nature. It stated that the complainant could have resorted to other available legal remedies to question the propriety of the award. An administrative complaint is not the appropriate venue for challenging a decision or order perceived as unjust or unreasonable. The respondent judge's reliance on the complainant's testimony and a POEA order awarding P3,000.00 was a matter of judicial discretion within the context of the case he was deciding. On the procedural issue of the administrative complaint: The Court implicitly affirmed that while administrative complaints can be filed against judges, they are not a substitute for appeals or other legal remedies to correct judicial errors or perceived injustices in decisions. The Court noted that the complaint was not under oath, which is a requirement under Section 1 of Rule 140 of the Revised Rules of Court, although it did not make this the primary basis for its decision regarding the substantive charges.
Main Doctrine
Judges must maintain control over court proceedings, adopt a firm policy against improvident postponements, and adhere to time limits for deciding cases. Administrative complaints are not the proper forum for questioning the propriety of a judicial decision or order perceived as unjust or unreasonable.