Cruz v. Ubiadas
REITERATIONFacts
The Antecedents: Complainant Chito M. Cruz charged respondent Judge Eliodoro G. Ubiadas with violation of Supreme Court Circular No. 20-95, tantamount to gross ignorance of the law. The Subic Bay Metropolitan Authority (SBMA), under new leadership, reviewed and terminated certain residential lease contracts deemed disadvantageous to the government. This led to ejectment cases filed by SBMA and, conversely, suits filed by occupants and a corporation seeking specific performance and to prevent contract cancellations. Several civil cases and one criminal case (People v. Esmane-Diaz for Falsification of Public Documents) were allegedly raffled to respondent judge without notice to SBMA. Procedural History: The complainant detailed several instances of alleged irregularities: denial of a motion to dismiss in Paglinawan v. SBMA despite SBMA's directive to accept payments; issuance of a TRO in Doropan v. SBMA without hearing, and failure to act on SBMA's motion to dismiss and dissolve the TRO; issuance of orders denying motions to dismiss in Doropan, Santos, Daduya, and Gordon cases due to alleged defective notice of hearing, despite one motion having a clear hearing date; issuance of preliminary injunctions in these four cases; failure to resolve urgent motions for reconsideration for over three years; denial of SBMA's motion for inhibition; and alleged irregular disqualification of a provincial fiscal in the criminal case. The Court of Appeals found respondent judge liable for evident partiality and violation of Supreme Court Circular No. 20-95, recommending a one-year suspension or equivalent fine. The Petition: The Supreme Court reviewed the resolution of the Court of Appeals, agreeing with the finding that respondent judge violated Supreme Court Circular No. 20-95, but disagreed on the penalty. The Court examined the alleged irregularities in the raffle of cases, the issuance of TROs and preliminary injunctions despite formal defects in the pleadings, and the delay in resolving pending motions.
Issue(s)
Whether respondent judge violated Supreme Court Circular No. 20-95 regarding the raffle of cases. Whether respondent judge committed gross ignorance of the law or evident partiality in issuing TROs and preliminary injunctions despite formal defects in the pleadings. Whether respondent judge incurred liability for undue delay in resolving cases. Whether the charge of irregularity in the disqualification of the provincial fiscal in the criminal case was sufficiently proven.
Ruling
The Supreme Court found respondent Judge Eliodoro G. Ubiadas liable for violating Supreme Court Circular No. 20-95 and imposed a fine of P15,000.00, with a stern warning against repetition of similar acts. The Court agreed with the Court of Appeals that the respondent violated S.C. Circular No. 20-95 and noted apparent irregularities in the issuance of TROs and preliminary injunctions. However, the Court found the charge of irregularity in the criminal case not sufficiently proven. The Court imposed a fine for the less serious charge of violating S.C. Circular No. 20-95, considering the respondent's positive record of service.
Ratio Decidendi
On the violation of Supreme Court Circular No. 20-95: The Court found that the respondent judge violated Supreme Court Circular No. 20-95, which requires raffling of cases to be conducted only after notice to the adverse party and in their presence. The respondent's contention that it was not his duty as vice-executive judge to ensure compliance was deemed disingenuous. Except for a few instances, the respondent failed to refute claims of irregularities in the raffle of cases. The Court emphasized that judges are required to observe due care, diligence, prudence, and circumspection, and their conduct must be beyond reproach. The failure to present minutes of the raffle for the subject cases further weakened the respondent's defense. The Court reiterated that judges are not repositories of arbitrary power but are under the sanction of law, and must not provide any opportunity to be perceived as abusing their authority. On the issuance of TROs and preliminary injunctions despite formal defects: The Court noted apparent irregularities in the issuance of TROs and preliminary injunctions, particularly the unjustified haste in granting injunctive relief despite patent defects in the petitions. The respondent judge granted outright 20-day TROs and preliminary injunctions despite glaring formal defects such as the absence of proper verification and certification of non-forum shopping. The Court stressed that the formal requirement of proper verification is indispensable, and counsel cannot sign for the plaintiffs except in exceptional cases. The alleged urgency was belied by the inaction for at least three months, raising suspicion that plaintiffs waited for the respondent judge's return from leave. Furthermore, reliefs were awarded without any showing that they were applied for, and included matters not prayed for in the applications. On undue delay in resolving cases: The respondent judge failed to act on motions for reconsideration that had been pending for more than three years, without providing any explanation. The Court reminded judges of the requirement to decide cases within ninety days after submission. The respondent admitted that most of the cases were still in the preliminary injunction stage, indicating a failure to comply with the mandated period for resolution. On the irregularity in the criminal case: The Court agreed that the charge of irregularity against the respondent in the criminal case was not sufficiently proven. Records showed that the respondent initially disqualified the provincial fiscal but later reconsidered his order upon verifying the fiscal's designation by the Ombudsman. This indicated a willingness to correct an error upon proper substantiation, rather than a deliberate act of irregularity.
Main Doctrine
A judge's failure to observe proper procedure in the raffle of cases and the issuance of TROs and preliminary injunctions, as well as delay in the resolution of cases, constitutes a violation of the Code of Judicial Conduct, amounting to gross ignorance of the law or procedure, or evident partiality, depending on the gravity of the offense.