Sta. Ana v. Arinday, Jr.
REITERATIONFacts
The Antecedents: Complainant Romeo Sta. Ana filed a letter-complaint against Judge Graciano H. Arinday, Jr. for delay in the resolution of Criminal Cases Nos. 3094-69 and 3095-69, which involved charges of estafa and violation of B.P. Blg. 22 against Minerva Ercilla. The prosecution had rested its case on October 11, 1994, and the accused waived her right to present evidence, yet no decision was rendered. Procedural History: The respondent judge, upon assuming office on May 31, 1994, inherited approximately 200 cases, including the two in question, with no prior hearings conducted. He claimed he delayed the resolution to allow for an amicable settlement, citing complainant's counsel's manifestation of openness to settlement and a similar instance where complainant had settled other cases. He also suggested the complainant was using the court as a collection agency. The Petition: The complainant countered that the judge himself suggested the settlement and that the accused's failure to respond should have prompted the judge to proceed. He alleged the judge's "lukewarm attitude" and "apparent partiality" led him to withdraw other cases. The core issue is whether the respondent judge was guilty of delay in deciding the cases.
Issue(s)
Whether respondent judge is guilty of delay in deciding Criminal Cases Nos. 3094-69 and 3095-69. Whether the respondent judge's reason for delay (amicable settlement) is justifiable.
Ruling
The Court resolved to docket the case as an administrative matter, impose a fine of P2,000.00 on Judge Graciano H. Arinday, Jr. with a warning, and direct him to resolve Criminal Cases Nos. 3094-69 and 3095-69 with deliberate speed.
Ratio Decidendi
On whether respondent judge is guilty of delay in deciding Criminal Cases Nos. 3094-69 and 3095-69: The Court found the respondent judge guilty of delay. The cases were submitted for resolution on October 11, 1994, and by September 23, 1995, when the judge submitted his comment, he admitted to only "started assessing the evidence through the records." This indicated a delay of nearly a year after submission, and the complaint was filed three years after the submission, with no decision in sight. The constitutional mandate requires lower courts to decide cases within three months from submission. On whether the respondent judge's reason for delay (amicable settlement) is justifiable: The Court found the respondent judge's excuse of waiting for an amicable settlement unpersuasive. While the desire to ease workload through settlement is understandable, three years is an excessive period to wait for such an arrangement. The law requires judges to decide cases within prescribed periods, and waiting indefinitely for settlement opens a judge to suspicion of partiality and bias. Such delays erode public faith in the judiciary.
Main Doctrine
A judge cannot wait indefinitely for parties to settle a case without opening himself to suspicion of partiality and bias, and delay in the disposition of cases erodes faith and confidence in the judiciary.