Relova v. Rosales
REITERATIONFacts
The Antecedents: Atty. Benjamin Relova charged Judge Antonio M. Rosales with violation of Supreme Court Circular No. 13-92 for the alleged failure to act on a Manager's Check amounting to ₱300,000.00 deposited for consignation in Civil Case No. C-351. The complainant alleged that the check had not been acted upon, neither approved nor disapproved, nor ordered deposited with a government depository bank, causing prejudice to the client and the National Treasury. Procedural History: Respondent judge argued that the case was harassment and that the decision to deposit the check was interwoven with his judicial function, which was hampered by the complainant's numerous petitions and motions for postponement. The Court of Appeals had previously ruled that claims for interest on the deposited check were premature. The case was pending before the Supreme Court. The Petition: The complainant charged the respondent judge with violation of Supreme Court Circular No. 13-92.
Issue(s)
Whether respondent judge violated Supreme Court Circular No. 13-92. Whether respondent judge is administratively liable for the failure to deposit the Manager's Check.
Ruling
The Supreme Court acquitted Judge Antonio M. Rosales of any administrative violation of Circular 13-92. However, he was advised to be more careful and diligent in the performance of his supervisory functions over his court personnel.
Ratio Decidendi
On the issue of whether respondent judge violated Supreme Court Circular No. 13-92 and incurred administrative liability: The Court ruled that judges cannot be directly faulted for the failure of the Clerk of Court to immediately deposit fiduciary funds as mandated by Supreme Court Circular No. 13-92. The Circular explicitly designates the Clerk of Court as the custodian responsible for depositing bail bonds, rental deposits, and other fiduciary collections with an authorized government depository bank. Judges are not typically involved in the day-to-day handling of these collections and would not ordinarily know when they are received by the Clerk of Court. Therefore, the Clerk of Court is the officer primarily mandated to perform this duty, and the judge's liability would only arise in cases of bad faith, malice, dishonesty, arbitrariness, or a clear failure to supervise. In this specific case, the Court found that the complainant failed to prove that the Manager's Check was received by the Clerk of Court as a cash equivalent to be deposited. The check was presented as a document and marked as Exhibit "N" by the complainant's client in the civil case. Since the check was not received directly as a fiduciary collection, the situation did not strictly fall under the administrative penalty provisions of SC Circular No. 13-92. Furthermore, the respondent judge, upon learning of the non-deposit, studied the matter and determined that the deposit was interwoven with the exercise of his judicial function, as the consignation case was still undecided and the check was an evidence. His decision not to deposit it immediately was not arbitrarily arrived at, nor was it patently erroneous, facetious, or unreasonable. Even if it were assumed that the check should have been deposited, the judge's inaction, in the absence of bad faith, does not warrant administrative sanction. Errors in judgment are not punishable unless they are gross, patent, malicious, deliberate, or in bad faith. The Court reiterated that defective or erroneous decisions or orders are presumed to have been issued in good faith in the absence of proof to the contrary. The respondent judge had no prior administrative offenses, and the alleged error was not gross or patent, nor was malice or corrupt motive shown. The most that could be said was that he should be more careful and diligent in supervising court personnel, as judges have supervisory powers over clerks of court and employees under them.
Main Doctrine
Judges cannot be directly faulted for the failure of the Clerk of Court to immediately deposit fiduciary funds as mandated by Supreme Court Circular No. 13-92, absent any showing of bad faith, malice, dishonesty, arbitrariness, or rank failure to supervise. The Clerk of Court is the custodian and is mandated to deposit such funds. A judge's inaction or erroneous decision regarding the deposit, if made in good faith and not patently erroneous, does not constitute administrative liability.