Vera Cruz v. Villegas
REITERATIONFacts
The Antecedents: Evangeline Vera Cruz filed an administrative complaint against Judge Winston M. Villegas for undue delay in rendering a decision or order, fraternizing with a litigant (Dra. Carmelita Vera Cruz, a co-defendant in Civil Case No. 192), and violation of the Code of Judicial Conduct. Evangeline alleged that her annulment of marriage case had not moved for over a year and discovered that the case record was in the judge's house. She also noted that the judge and her co-defendant, Dra. Carmelita Vera Cruz, lived in the same barangay, raising suspicions of impropriety. Evangeline also filed a petition for change of venue, citing her apprehension of receiving a fair hearing and the case's slow progress since its filing in 2003, remaining on pre-trial for almost five years. Procedural History: Judge Villegas, in his comment, denied fraternizing with Carmelita, stating their houses were about 250 meters apart. He attributed the delay to a heavy caseload and a temporary power outage. He also revealed that Evangeline's marriage had already been declared null and void by another RTC in 1986, a fact not disclosed in her complaint, and that the defendant, Lorenzo Vera Cruz, had moved to dismiss the case on this ground. Evangeline later discovered that the declaration of nullity had been annotated on her marriage contract in 2008, twenty years after the decision, and speculated about connivance in its belated registration. The Petition: The Office of the Court Administrator (OCA) found Judge Villegas guilty of undue delay in resolving Lorenzo's Motion to Dismiss and failing to progress the case beyond pre-trial for almost five years. The OCA recommended a fine of ₱5,000.00. However, the OCA recommended dismissal of the charges for violation of the Code of Judicial Conduct and fraternizing with a litigant due to lack of evidence. The OCA also recommended denying Evangeline's petition for change of venue. The Court re-docketed the complaint as a regular administrative matter and required parties to manifest willingness to submit the case on pleadings.
Issue(s)
Whether Judge Villegas is guilty of undue delay in rendering a decision or order. Whether Judge Villegas is guilty of fraternizing with a litigant. Whether Judge Villegas violated the Code of Judicial Conduct. Whether Evangeline's petition for change of venue should be granted.
Ruling
The Court found Judge Winston M. Villegas guilty of undue delay in rendering a decision in Civil Case No. 192 and imposed a fine of ₱15,000.00, with a stern warning against the commission of a similar offense. The charges of violating the Code of Judicial Conduct and fraternizing with a litigant were dismissed for lack of evidence. Evangeline's petition for change of venue was also denied.
Ratio Decidendi
On the charge of undue delay in rendering a decision or order: The Court affirmed the OCA's finding that Judge Villegas was guilty of undue delay. Records showed that Civil Case No. 192 was filed on March 6, 2003, and the last hearing was on July 6, 2006. It was only on December 27, 2007, over a year later, that the respondent judge issued an order denying the Motion to Dismiss and setting the case for pre-trial. This clearly exceeded the 90-day reglementary period for resolving motions. Furthermore, the case remained on the pre-trial stage for almost five years since its filing. The respondent's contentions regarding a heavy caseload and a power outage were deemed untenable as justifications for the delay. The Court emphasized that "justice delayed is justice denied" and that failure to decide or resolve motions within the reglementary period constitutes gross inefficiency. Undue delay is classified as a less serious charge, and considering it was Judge Villegas' first offense, a fine was deemed more appropriate than suspension. The Court imposed a fine of ₱15,000.00, considering the substantial delay in the case's progress. On the charges of violation of the Code of Judicial Conduct and fraternizing with a litigant: The Court dismissed these charges for failure to adduce substantial evidence. As correctly concluded by the OCA, charges based on mere suspicion and speculation cannot be given credence. Evangeline's allegations regarding the proximity of the judge's residence to that of the co-defendant, Dra. Carmelita Vera Cruz, and her suspicions about their relationship were not substantiated by concrete proof. Therefore, without sufficient evidence to establish fraternization or any other violation of the Code of Judicial Conduct, these charges had to be dismissed. On the charges of violation of the Code of Judicial Conduct and fraternizing with a litigant: The Court dismissed these charges for failure to adduce substantial evidence. As correctly concluded by the OCA, charges based on mere suspicion and speculation cannot be given credence. Evangeline's allegations regarding the proximity of the judge's residence to that of the co-defendant, Dra. Carmelita Vera Cruz, and her suspicions about their relationship were not substantiated by concrete proof. Therefore, without sufficient evidence to establish fraternization or any other violation of the Code of Judicial Conduct, these charges had to be dismissed. On the petition for change of venue: The Court denied Evangeline's petition for change of venue. The reasons advanced by Evangeline, such as being a stranger to Dumaguete City and her apprehension about receiving a fair hearing after filing the administrative complaint, were not considered sufficiently compelling and weighty to justify a change of venue. The Court reiterated that a change of venue is an extraordinary remedy that requires a strong showing of necessity to prevent a miscarriage of justice, which was not demonstrated in this case.
Main Doctrine
A judge is liable for undue delay in resolving a motion if it is not decided within the 90-day reglementary period. Mere suspicion and speculation are insufficient to prove charges of violation of the Code of Judicial Conduct or fraternizing with a litigant.