The Supreme Court in this case addresses the administrative liability of a Justice of the Court of Appeals for undue delay in resolving a motion for inhibition. The Court ruled that failure to promptly act on a motion, even considering external factors, constitutes a violation of judicial duties, warranting disciplinary action. This decision underscores the judiciary’s commitment to timely dispensation of justice and reinforces the principle that delays in resolving even procedural matters can significantly impact the fairness and efficiency of the legal process. The ruling serves as a reminder to members of the bench about their constitutional mandate to resolve matters expeditiously.

Justice Delayed: When a Motion for Inhibition Languished, Raising Questions of Impartiality

This case arose from a dispute within Alabang Country Club, Inc. (ACCI), where Ramon C. Gonzales, a member, faced disqualification from running for a seat on the Board of Directors. Gonzales filed a civil case against ACCI, which eventually reached the Court of Appeals. In the appellate court, Associate Justice Amelita G. Tolentino, as ponente, issued a Writ of Preliminary Injunction against the execution of the lower court’s decision favoring Gonzales. Gonzales, believing the issuance of the writ was unlawful, filed a Motion for Inhibition against Justice Tolentino. The motion, filed on September 29, 2005, remained unresolved for years, prompting Gonzales to file a complaint before the Supreme Court, alleging undue delay and raising concerns about Justice Tolentino’s impartiality due to alleged connections with a lawyer involved in the case. This situation brings to the forefront the importance of judicial accountability and the need for timely resolution of motions that question a judge’s impartiality.

The core issue before the Supreme Court was whether Justice Tolentino’s delay in resolving the Motion for Inhibition constituted a violation of her duties as a member of the judiciary. Gonzales argued that the delay was not only a breach of judicial responsibility but also indicative of bias, given the alleged connections between Justice Tolentino and a certain Atty. Felisberto Verano, who was purportedly linked to a congresswoman who had supported Justice Tolentino’s appointment. The complainant highlighted that resolutions issued in the case were also furnished to Atty. Verano, who was not even a counsel of record in the case nor has he entered formally his appearance. The Supreme Court needed to determine if these circumstances warranted disciplinary action against Justice Tolentino.

Justice Tolentino defended her inaction by arguing that the filing of a Petition for Certiorari before the Supreme Court on September 8, 2005, regarding the issuance of the writ of preliminary injunction, justified her deferral of any action on the Motion for Inhibition filed on September 29, 2005. She claimed that she deemed it appropriate to defer any action on the motion in deference to the authority of this Court to resolve the issues raised before it. She also contended that there was nothing anomalous in furnishing Atty. Verano with copies of the resolutions, as he was a collaborating counsel in the case. However, the Supreme Court found these justifications unconvincing. The Court emphasized that a Petition for Certiorari does not automatically interrupt the proceedings in the lower court unless a restraining order is issued. The Court cited Go v. Looyuko, G.R. No. 147923, October 26, 2007, 537 SCRA 445, 480-481, and Republic v. Sandiganbayan, G.R. No. 166859, June 26, 2006, 492 SCRA 747, stating that this rule must be strictly adhered to by appellate and lower courts notwithstanding the possibility that the proceedings undertaken by them tend to or would render nugatory the pending petition before this Court.

Building on this principle, the Supreme Court highlighted the constitutional mandate for the timely resolution of cases. Article VIII, Section 15 (1) of the Constitution explicitly directs that lower collegiate courts must resolve cases or matters within twelve months. The Court noted that even if Justice Tolentino’s justification were accepted, the delay in resolving the Motion for Inhibition was still excessive. The Supreme Court resolved the Petition for Certiorari on April 11, 2007, yet Justice Tolentino only acted on the Motion for Inhibition on October 8, 2008, after the administrative complaint was filed. This delay was deemed unacceptable and a violation of judicial duties.

The Supreme Court also addressed the issue of furnishing resolutions to Atty. Verano. While the Court acknowledged that Atty. Verano had signed the Petition for Review as collaborating counsel, it reiterated that the order to issue the writ of preliminary injunction was a collective decision of the Ninth Division of the Court of Appeals. Citing Bautista v. Abdulwahid, A.M. OCA I.P.I No. 06-97-CA-J, May 2, 2006, 488 SCRA 428, the Court stated that a charge of violation of the Anti-Graft and Corrupt Practices Act on the ground that a collective decision is “unjust” cannot prosper. Consequently, the filing of charges against a single member of a division of the appellate court is inappropriate. Thus, the Court focused primarily on the delay in resolving the motion, rather than the propriety of issuing the writ itself.

In its analysis, the Supreme Court referenced Rule 140 of the Rules of Court, which governs the discipline of judges and justices. Section 9 (1) of Rule 140 classifies undue delay in rendering a decision or order as a less serious charge. Section 11 (B) of the same rule outlines the sanctions that may be imposed, including suspension or a fine. Considering the circumstances, the Court determined that a fine was the appropriate penalty. The Court emphasized the importance of timely resolution of motions, especially those concerning potential conflicts of interest, to maintain public trust in the impartiality of the judiciary. Here’s a summary of the Court’s considerations:

Issue	Court’s Finding
Delay in Resolving Motion for Inhibition	Unjustified and violated judicial duties
Furnishing Resolutions to Atty. Verano	Not anomalous as he was a collaborating counsel

The Supreme Court ultimately found Justice Tolentino guilty of undue delay in rendering an order. The Court imposed a fine of Fifteen Thousand Pesos (P15,000) and issued a warning that any similar infractions in the future would be dealt with more severely. This decision reinforces the judiciary’s commitment to upholding the standards of judicial conduct and ensuring that all matters brought before the courts are resolved in a timely and efficient manner. It serves as a reminder to all judges and justices of their responsibility to act promptly on all pending motions and cases, as delays can erode public confidence in the justice system.

FAQs

What was the key issue in this case?	The key issue was whether Associate Justice Amelita G. Tolentino of the Court of Appeals was administratively liable for undue delay in resolving a Motion for Inhibition filed against her.
Why was the Motion for Inhibition filed?	The motion was filed by Ramon C. Gonzales, who believed that Justice Tolentino’s issuance of a Writ of Preliminary Injunction was against the law and that she had potential conflicts of interest due to alleged connections with a lawyer involved in the case.
What was Justice Tolentino’s defense for the delay?	Justice Tolentino argued that she deferred action on the Motion for Inhibition because a Petition for Certiorari related to the same case was pending before the Supreme Court.
Did the Supreme Court accept Justice Tolentino’s defense?	No, the Supreme Court did not accept her defense, stating that a Petition for Certiorari does not automatically interrupt proceedings in the lower court and that the delay was still excessive even after the Supreme Court resolved the Petition for Certiorari.
What rule of the Rules of Court did the Supreme Court cite?	The Supreme Court cited Rule 140 of the Rules of Court, which governs the discipline of judges and justices, and classifies undue delay in rendering a decision or order as a less serious charge.
What was the Supreme Court’s ruling in this case?	The Supreme Court found Justice Tolentino guilty of undue delay in rendering an order and imposed a fine of Fifteen Thousand Pesos (P15,000), with a warning that any similar infractions in the future would be dealt with more severely.
What is the significance of this ruling?	The ruling underscores the judiciary’s commitment to timely dispensation of justice and reinforces the principle that delays in resolving even procedural matters can significantly impact the fairness and efficiency of the legal process.
What action was taken after the complaint was filed?	After the complaint was filed, Justice Tolentino inhibited herself from the case.

This case serves as a crucial reminder of the responsibilities of members of the judiciary to act promptly and efficiently in resolving all matters brought before them. The Supreme Court’s decision reinforces the importance of maintaining public trust in the judicial system through timely and impartial decision-making.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: RAMON C. GONZALES vs. COURT OF APPEALS ASSOCIATE JUSTICE AMELITA G. TOLENTINO, A.M. No. CA-10-49-J, January 28, 2010