Enalbes v. Leonardo-De Castro
REITERATIONFacts
The Antecedents: This administrative matter arose from a Complaint-Affidavit filed by Elvira N. Enalbes, Rebecca H. Angeles, and Estelita B. Ocampo against former Chief Justice Teresita J. Leonardo-De Castro. The complainants accused the former Chief Justice of gross ignorance of the law, gross inefficiency, gross misconduct, gross dishonesty, and conduct prejudicial to the best interest of the service. The core of their complaint was the alleged failure of the former Chief Justice to decide two petitions filed by Spouses Eligio P. Mallari and Marcelina I. Mallari, which had been pending for over five years. Procedural History: The underlying dispute began with the Mallari Spouses filing a Petition for Mandamus and Prohibition with Prayer for Temporary Restraining Order on September 4, 2012, docketed as G.R. No. 203063. Subsequently, on January 25, 2013, they filed a Petition for Review on Certiorari, docketed as G.R. No. 204743. Both petitions were assigned to the Supreme Court's First Division and were subsequently raffled to then Chief Justice De Castro. The complainants averred that despite the passage of more than five years, no decision was rendered on these petitions, leading them to file the instant administrative complaint. The Petition: The complainants alleged that the former Chief Justice's failure to promptly act on the Mallari Spouses' petitions violated their constitutional right to a speedy disposition of cases. They further argued that this inaction constituted graft and corruption, specifically by giving unwarranted benefits to the Philippine National Bank through manifest partiality, evident bad faith, or gross inexcusable negligence, thereby causing undue injury to the Mallari Spouses. The administrative complaint sought to hold the former Chief Justice liable for these alleged offenses.
Issue(s)
Whether respondent former Chief Justice Teresita J. Leonardo-De Castro should be held administratively liable for gross ignorance of the law, gross inefficiency, gross misconduct, gross dishonesty, and conduct prejudicial to the best interest of the service for failing to decide the Mallari Spouses' petitions within five years; and whether her mandatory retirement renders the administrative complaint moot. Whether the failure to decide cases within the constitutional period constitutes a violation of the right to speedy disposition of cases and warrants administrative sanctions.
Ruling
The administrative complaint against former Chief Justice Teresita J. Leonardo-De Castro is DISMISSED. There is no showing of a prima facie case against her. Furthermore, the respondent had already vacated her office due to mandatory retirement on October 10, 2018, rendering the administrative complaint moot.
Ratio Decidendi
On Issue 1: The Court held that the constitutional period for deciding cases, as provided in Article VIII, Section 15 of the 1987 Constitution, is directory and not mandatory. This period commences from the date of submission, which is defined as the filing of the last pleading, brief, or memorandum. The respondent's mandatory retirement on October 10, 2018, rendered the administrative complaint moot and academic, as she had already vacated her office. On Issue 2: The Court emphasized that a mere mathematical reckoning of the time involved is insufficient to determine a violation of the right to speedy disposition of cases, as this right is a relative or flexible concept. Magistrates must be given discretion to defer the disposition of certain cases to make way for other important matters, and justice does not equate to hastily giving one's due if it is found to be prejudicial. The Court cited Marcelino v. Hon. Cruz, Jr., etc. et al. and De Roma v. Court of Appeals which established that similar constitutional provisions under the 1973 Constitution were merely directory. Therefore, the respondent's failure to promptly resolve the Mallari Spouses' petitions did not constitute gross ignorance of the law or gross inefficiency warranting administrative liability.
Main Doctrine
The Court reiterated that the 24-month period prescribed by Article VIII, Section 15 of the 1987 Constitution for deciding cases is directory, not mandatory. This period commences from the date of submission, which is upon the filing of the last pleading, brief, or memorandum. Consequently, a mere failure to decide within this period does not automatically render a magistrate liable for gross ignorance of the law or gross inefficiency, as the right to speedy disposition of cases is a relative concept that requires a holistic assessment beyond mere mathematical reckoning of time.