“To hold a magistrate administratively liable for gross ignorance of the law, it is not enough that his or action was erroneous; it must also be proven that it was driven by bad faith, dishonesty, or ill motive.” Thus held the Supreme Court as it recently dismissed an administrative complaint against retired Chief Justice Teresita J. Leonardo-de Castro “as there is no showing of prima facie case against her.”
In a nine-page resolution penned by Justice Marvic M.V.F Leonen, the Court En Banc further held that Chief Justice de Castro’s mandatory retirement on October 10, 2018 also rendered complainants’ administrative complaint moot.
The case stemmed from the complaint filed by Elvira N. Enalbes, Rebecca H. Angeles, and Estelita B. Ocampo, who accused Chief Justice de Castro of gross ignorance of the law, gross inefficiency, gross misconduct, gross dishonesty, and conduct prejudicial to the best interest of the service for the latter’s alleged failure to decide despite the lapse of more than five years two separate petitions filed by Spouses Eligio P. Mallari and Marcelina I. Mallari in 2012 and 2013, respectively.
The Court ruled that complainants’ arguments, which relied on Article VIII, Section 15 of the 1987 Constitution requiring the Supreme Court to decide on cases within 24 months from their submission, lack merit. It noted that as stated in the 1987 Constitution and the Internal Rules of Court, the reckoning of the 24-month period begins only when the last pleading, brief, or memorandum when the last pleading, brief, or memorandum has been submitted before it. Moreover, the Court held that “(w)hile the 24-month period provided under the 1987 Constitution is persuasive, it does not summarily bind this Court to the disposition of cases brought before it. It is a mere directive to ensure this Court’s prompt resolution of cases, and should not be interpreted as an inflexible rule,” citing the doctrine it laid down in Marcelino and De Roma.
The Court stressed that it, being the court of last resort, “should be given an ample amount of time to deliberate on cases pending before it. Ineluctably, leeway must be given to magistrates for them to thoroughly review and reflect on the cases assigned to them. This Court note that all matters brought before it involves rights which are legally demandable and enforceable. It would be at the height of injustice if cases were hastily decided on at the risk of erroneously dispensing justice.”
As a final note, the Court ruled that the prescribed time limit should not be ignored as to render nugatory the spirit which breathes life to the letter of the 1987 Constitution. “Ultimately, courts must strike an objective and reasonable balance in disposing cases promptly, while maintaining judicious tenacity in interpreting and applying the law,” it said. (A.M. No. 18-11-09-SC, 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. 203063 and 204743, January 22, 2019)