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PEOPLE v. EUSTAQUIO Z. GACOTT

FACTS:

The respondent Judge Eustaquio Z. Gacott, Jr. filed a motion for reconsideration and a supplemental motion for reconsideration after the Court annulled his order dismissing Criminal Case No. 11529. Copies of the motions were furnished to various officials and entities, including the individual members of the Court. The Court emphasized that the only issue to be resolved was whether or not the respondent judge gravely abused his discretion in granting the motion to quash the criminal case. The Court found that the respondent judge's error in dismissing the case was obvious as the intent to abolish the Anti-Dummy Board was clearly expressed in the law. The Court also held that the respondent judge's error amounted to gross ignorance of the law and that the arguments raised in his motions were refuted by previous cases. The respondent judge requested for the decision to not be spread on his personal records, but the Court rejected this argument and stated that the decision must appear in official documents. The Court also noted that the respondent judge sent copies of his motions to several individuals, contradicting his claim about the confidential nature of disciplinary cases.

ISSUES:

  1. Whether or not the transfer of the case to the Second Division of the Supreme Court without informing the parties is valid.

  2. Whether or not the Second Division of the Supreme Court has the competence to administratively discipline the respondent judge.

  3. What is the scope of the disciplinary power of the Supreme Court en banc?

  4. Is it necessary for the entire Court to deliberate upon and participate in all administrative matters or cases regardless of the sanctions imposed?

  5. Under what circumstances can an administrative matter be decided by a division of the Court?

RULING:

  1. The transfer of the case to the Second Division without informing the parties is valid. There is no requirement in the Court's rules that parties be informed of the transfer of a case to another division to protect the identity of the ponente and prevent speculation.

  2. The Second Division of the Supreme Court has the competence to administratively discipline the respondent judge. The provision cited by the respondent judge from the Constitution only requires the Supreme Court en banc, not a division thereof, to have the power to discipline judges of lower courts.

  3. The first clause of Section 11 of Article VIII provides that "the Supreme Court en banc shall have the power to discipline judges of lower courts." This clause grants the disciplinary power to, and determines the procedure for its exercise by, the Court en banc. However, it is not intended that all administrative disciplinary cases be heard and decided by the whole Court.

  4. Requiring the entire Court to deliberate upon and participate in all administrative matters or cases would result in congestion and delay. Thus, only cases involving the dismissal of judges of lower courts are specifically required to be decided by the Court en banc.

  5. Administrative matters in which the penalty imposed does not exceed suspension of more than one year or a fine of P 10,000.00, or both, may be decided by a division of the Court.

PRINCIPLES:

  • Administrative penalties do not determine the end of a public career.

  • Copies of motions filed with the court are only furnished to the adverse party.

  • The Supreme Court observes the raffle of its cases and abides by the result faithfully.

  • The transfer of a case to another division does not require informing the parties.

  • The Supreme Court en banc has the power to discipline judges of lower courts.

  • The Supreme Court en banc is not the only division that can administratively punish judges.

  • The disciplinary power of the Supreme Court en banc extends to judges of lower courts.

  • Administrative matters involving the dismissal of judges of lower courts must be decided by the Court en banc.

  • Only cases involving the dismissal of judges are required to be decided by the Court en banc.

  • Administrative matters with penalties not exceeding suspension of more than one year or a fine of P 10,000.00, or both, may be decided by a division of the Court.

  • Requiring the entire Court to decide all administrative matters would result in congestion and delay.