RE: COMPLAINT-AFFIDAVIT OF ELVIRA N. ENALBES, REBECCA H. ANGELES AND ESTELITA B. OCAMPO AGAINST FORMER CHIEF JUSTICE TERESITA J. LEONARDO-DE CASTRO [RET.], RELATIVE TO G.R. NOS.…

Enalbes versus Leonardo-De Castro

The Case

This is an administrative matter arising 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 charged the former Chief Justice with gross ignorance of the law, gross inefficiency, gross misconduct, gross dishonesty, and conduct prejudicial to the best interest of the service, all on the theory that she failed to promptly resolve two petitions of the Mallari Spouses that had been raffled to her. The case matters because it is the Supreme Court's own statement on the meaning of the constitutional period for deciding cases: the twenty-four month period is counted from submission for resolution, and it is directory, not an inflexible rule that strips a magistrate of authority or fastens administrative liability for mere delay.

Procedural History

The matter began as an original administrative complaint filed directly with the Supreme Court, not as an ordinary action in a trial court. There were no proceedings in a lower court and no appeal; the complaint-affidavit was docketed as an administrative matter and resolved by the Supreme Court en banc. The Court treated the sole issue as whether the respondent should be held administratively liable on the charges alleged, and it resolved that question in this decision.

Facts

On September 4, 2012, Spouses Eligio P. Mallari and Marcelina I. Mallari filed before the Supreme Court a Petition for Mandamus and Prohibition with a prayer for a temporary restraining order. That petition was directed against the Court of Appeals First Division, represented by then Presiding Justice Andres B. Reyes, Jr., together with Associate Justices Ramon M. Bato, Jr. and Rodil V. Zalameda, and against the Court of Appeals Special Former Fourth Division of Five, likewise represented by Presiding Justice Reyes, together with Associate Justices Noel G. Tijam, Socorro B. Inting, Edwin D. Sorongon, and Agnes Reyes-Carpio.

On January 25, 2013, the Mallari Spouses filed a Petition for Review on Certiorari before the Supreme Court against the Philippine National Bank and the Court of Appeals Special Former Fourth Division of Five. Both petitions were assigned to the Court's First Division and were raffled to then Chief Justice De Castro.

The complainants alleged that despite the lapse of more than five years, the respondent failed to decide both petitions, and that this violated the spouses' constitutional right to speedy disposition of their cases. They further argued that the respondent committed graft and corruption by giving the Philippine National Bank unwarranted benefits through manifest partiality, evident bad faith, or gross inexcusable negligence, causing undue injury to the Mallari Spouses. The respondent had, by October 10, 2018, vacated her office upon her mandatory retirement.

Issues

• Whether or not 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.
• Whether or not the twenty-four month period for deciding cases runs immediately upon the filing of a petition, or only from the date of submission for resolution.
• Whether or not the constitutional period for deciding cases is mandatory and jurisdictional, such that failure to decide on time constitutes gross ignorance of the law.

Applicable Provisions

Article VIII, Section 15 of the 1987 Constitution provides:

SECTION 15. (1) All cases or matters filed after the effectivity of this Constitution must be decided or resolved within twenty-four months from date of submission for the Supreme Court, and, unless reduced by the Supreme Court, twelve months for all lower collegiate courts, and three months for all other lower courts. (2) A case or matter shall be deemed submitted for decision or resolution upon the filing of the last pleading, brief, or memorandum required by the Rules of Court or by the court itself.

This is the provision the complainants invoked, and its reckoning point, submission for resolution, is the heart of the ruling.

Rule 13, Section 1 of the Internal Rules of the Supreme Court provides:

SECTION 1. Period for Deciding or Resolving Cases. - The Court shall decide or resolve all cases within twenty-four months from the date of submission for resolution. A case shall be deemed submitted for decision or resolution upon the filing of the last pleading, brief, or memorandum that the Court or its Rules require.

The Internal Rules repeat the same reckoning, confirming that the period does not begin at filing.

Article X, Section 11 of the 1973 Constitution, the predecessor provision construed in the earlier cases, provides:

SECTION 11. (1) Upon the effectivity of this Constitution, the maximum period within which a case or matter shall be decided or resolved from the date of its submission, shall be eighteen months for the Supreme Court, and, unless reduced by the Supreme Court, twelve months for all inferior collegiate courts, and three months for all other inferior courts.

The Court looked back to this provision and to the doctrine that it is merely directory.

Rule 140, Section 11 of the Rules of Court, on sanctions for serious charges, provides:

SECTION 11. Sanctions. - A. If the respondent is guilty of a serious charge, any of the following sanctions may be imposed: Dismissal from the service, forfeiture of all or part of the benefits as the Court may determine, and disqualification from reinstatement or appointment to any public office, including government-owned or controlled corporations. Provided, however, that the forfeiture of benefits shall in no case include accrued leave credits; Suspension from office without salary and other benefits for more than three (3) but not exceeding six (6) months; or A fine of more than P20,000.00 but not exceeding P40,000.00.

This fixes the gravity of the charge of gross ignorance of the law, which the complainants pressed.

Ruling

On the first issue, the Court held that gross ignorance of the law is the failure of a magistrate to apply basic rules and settled jurisprudence; it connotes a blatant disregard of clear and unambiguous provisions of law because of bad faith, fraud, dishonesty, or corruption. To hold a magistrate liable, it is not enough that the action was erroneous; it must also be proven that it was driven by bad faith, dishonesty, or ill motive. No such showing was made here.

On the second issue, the Court held that under both the Constitution and the Internal Rules, the twenty-four month period is reckoned from the date of submission for resolution. It does not run immediately upon the filing of a petition, but only when the last pleading, brief, or memorandum has been submitted.

On the third issue, the Court held that the period is persuasive but does not summarily bind the Court; it is a mere directive to ensure prompt resolution and should not be read as an inflexible rule. Leeway must be given to magistrates to thoroughly review and reflect, for it would be at the height of injustice if cases were hastily decided at the risk of erroneously dispensing justice. The right to speedy disposition is a relative and flexible concept, so that a mere mathematical reckoning of time is not sufficient. The Court balanced this against the command of the Constitution, holding that the prescribed period should not be ignored as to render nugatory its spirit, and that courts must strike an objective and reasonable balance between promptness and judicious tenacity. Accordingly, the respondent's failure to promptly resolve the petitions did not constitute gross ignorance of the law warranting administrative liability; and in any event, her mandatory retirement on October 10, 2018 rendered the complaint moot.

Doctrine

• The twenty-four month period under Article VIII, Section 15 of the 1987 Constitution is counted from submission for resolution, that is, from the filing of the last pleading, brief, or memorandum required by the Rules or by the court itself, not from the filing of the petition.
• That period is directory, not jurisdictional; non-compliance does not invalidate the proceedings or automatically fasten administrative liability.
• Gross ignorance of the law requires not only an erroneous act but proof of bad faith, dishonesty, fraud, or ill motive; a serious charge under Rule 140 carries the sanctions of dismissal, suspension, or fine.
• The right to speedy disposition of cases is a relative and flexible concept; a mathematical reckoning of time alone does not establish a violation.

Disposition

The administrative complaint against former Chief Justice Teresita J. Leonardo-De Castro was dismissed for lack of a showing of a prima facie case against her.

Remember This

The line to memorize: the twenty-four month period runs from submission for resolution, and it is directory, so delay alone is not gross ignorance of the law. Examiners use this case to test the reckoning of the constitutional period for deciding cases and the elements of gross ignorance of the law as an administrative charge.