In Atty. Carlos D. Cinco v. Presiding Judge Alfonso C. Ruiz II, the Supreme Court addressed the issue of undue delay by a judge in resolving a formal offer of evidence. The Court found Judge Ruiz guilty of Undue Delay in Rendering a Decision/Order but admonished him, considering the circumstances and it being his first offense. This ruling underscores the judiciary’s commitment to timely resolution of legal matters while acknowledging the complexities judges face in ensuring fair proceedings.

Justice Delayed, Justice Denied: Did the Judge’s Pace Prejudice the Plaintiff?

The case originated from a complaint filed by Atty. Carlos D. Cinco against Judge Alfonso C. Ruiz II, alleging gross ignorance of the law, gross inefficiency, and violation of the Code of Judicial Conduct. The core of the complaint centered on the delay in resolving the Plaintiff’s Additional Formal Offer of Evidence (Rebuttal) and the denial of the admission of certain exhibits. Atty. Cinco contended that the delay of over nine months and the denial of exhibits attached to his Amended Judicial Affidavit prejudiced his client’s case.

Atty. Cinco argued that the exhibits should have been admitted because the defendants and intervenor waived their right to cross-examine him on his Amended Judicial Affidavit, implying acceptance of its contents, including the exhibits. He further asserted that his Amended Judicial Affidavit included motions to mark the attached exhibits, which the respondent judge ignored. In response, Judge Ruiz explained that the delay was not intentional, but rather an attempt to provide the complainant with an opportunity to rectify the defect of not marking the documents properly. He stated that he had set a clarificatory hearing for this purpose, but the complainant failed to attend.

Moreover, Judge Ruiz noted that even after the complainant failed to attend the clarificatory hearing, he allowed the filing of a rejoinder to address the defendants’ opposition. The judge claimed he was waiting for the complainant to realize the need for a motion to mark the exhibits. It was only upon receiving the complainant’s Ex-Parte Motion to Resolve that the court felt compelled to rule on the Formal Offer, ultimately denying the admission of the unmarked exhibits. The judge emphasized that it was the complainant’s duty to have the exhibits marked at the time of his testimony, which he failed to do.

The Office of the Court Administrator (OCA) investigated the complaint and recommended that Judge Ruiz be found guilty of Undue Delay in Rendering a Decision/Order. The OCA acknowledged the delay but also considered the judge’s explanation and apparent good faith. The OCA Report stated:

x x x In the case at hand, while the matter denying the admission of the exhibits in the formal offer is judicial in nature, it cannot be denied that respondent Judge incurred delay in resolving complainant’s formal offer. In fact, he categorically admitted the delay and explained that he only wanted to give the plaintiff ample time to properly mark the exhibits attached to its amended judicial affidavit for rebuttal.

The Supreme Court adopted the OCA’s findings, emphasizing the importance of timely resolution of cases. The Court cited Section 9(1), Rule 140 of the Rules of Court, which considers undue delay in rendering a decision or order as a less serious offense. The Court also cited Section 11(B) thereof, which provides for the penalties. However, considering the circumstances, the Court deemed it proper to admonish the respondent judge, acknowledging his good intentions and the fact that it was his first offense.

The Supreme Court, in this case, reiterated the importance of judges adhering to the prescribed periods for resolving pending incidents. While judges are given leeway to manage their dockets and ensure a fair hearing for all parties, this discretion must be exercised judiciously and without undue delay. The court has previously stated, “Good faith and lack of malicious intent cannot completely free respondent Judge from liability.” (Citing Ting v. Atal, 301 Phil. 82, 85 (1994)). Thus, even when a judge acts with good intentions, delays in resolving matters can still warrant administrative sanctions.

This case serves as a reminder to judges to balance the need for thoroughness and fairness with the imperative of timely justice. It also highlights the importance of counsel properly presenting their evidence and complying with procedural requirements. The failure to mark exhibits, as in this case, can lead to their exclusion, potentially prejudicing a party’s case.

Ultimately, the Court’s decision in Atty. Carlos D. Cinco v. Presiding Judge Alfonso C. Ruiz II reinforces the principle that justice delayed is justice denied. While the Court acknowledged the judge’s good intentions and mitigating circumstances, it emphasized the need for diligence and efficiency in the administration of justice. The admonishment serves as a reminder to all judges to prioritize the timely resolution of cases and to avoid unnecessary delays that can undermine public confidence in the judiciary.

FAQs

What was the key issue in this case?	The key issue was whether Judge Ruiz was administratively liable for delaying the resolution of Atty. Cinco’s formal offer of evidence and for denying the admission of exhibits.
What was the complainant’s main argument?	Atty. Cinco argued that Judge Ruiz took more than nine months to resolve the formal offer of evidence and improperly denied the admission of exhibits attached to his Amended Judicial Affidavit.
What was the respondent judge’s defense?	Judge Ruiz argued that the delay was not intentional, and he was giving the complainant an opportunity to properly mark the exhibits. He claimed that the complainant failed to do so, leaving him no choice but to deny their admission.
What did the Office of the Court Administrator (OCA) recommend?	The OCA recommended that Judge Ruiz be found guilty of Undue Delay in Rendering a Decision/Order and be admonished.
What was the Supreme Court’s ruling?	The Supreme Court adopted the OCA’s findings and admonished Judge Ruiz, with a stern warning against future delays.
What is the significance of marking exhibits in court proceedings?	Marking exhibits is a crucial step in presenting evidence, as it formally identifies and authenticates the documents or objects being offered as proof. Failure to do so can result in their exclusion from the case.
What is the penalty for undue delay in rendering a decision or order?	Under Rule 140 of the Rules of Court, undue delay is considered a less serious offense, punishable by suspension from office or a fine.
Can a judge be excused from liability for delay if they acted in good faith?	While good faith and lack of malicious intent may be considered as mitigating factors, they do not completely excuse a judge from liability for undue delay.
What is an Amended Judicial Affidavit?	An Amended Judicial Affidavit is a sworn statement that serves as a witness’s direct testimony in court. It can be amended to correct errors or include additional information.
What is the role of the Office of the Court Administrator (OCA)?	The OCA is responsible for the supervision and administration of all courts in the Philippines. It investigates complaints against judges and court personnel and makes recommendations to the Supreme Court.

This case reinforces the judiciary’s commitment to ensuring the efficient and timely administration of justice. While judges are afforded discretion in managing their dockets, they must exercise this discretion judiciously and avoid unnecessary delays that can prejudice litigants and undermine public trust in the legal system.

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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: ATTY. CARLOS D. CINCO v. PRESIDING JUDGE ALFONSO C. RUIZ II, A.M. No. RTJ-16-2482, August 15, 2018