## FACTS:

Petitioners in this case are Judge Ana Maria I. Dolalas, Evelyn K. Obido, and Wilberto B. Carriedo - Presiding Judge, Clerk of Court and Clerk II, respectively of the Municipal Circuit Trial Court of Kabasalan, Zamboanga del Sur. They were charged "administratively" by private respondent Benjamin Villarante, Jr. for "miscarriage of justice, dishonesty, gross neglect of duty, unnecessary delay in the administration of justice and for failure to prosecute Criminal Case No. 5881 for an unreasonable length of time" before the Office of the Ombudsman-Mindanao. The complaint arose from a criminal case filed against private respondent by a police officer, in which private respondent alleged that there have been no pre-conference, arraignment or pre-trial held or conducted by petitioner judge. Private respondent also claimed that the criminal case filed against him has been unnecessarily delayed, prejudicing his constitutional right to an impartial investigation and a fair and speedy trial. Petitioners filed a motion to dismiss and a motion for reconsideration, but these were denied by the Office of the Ombudsman-Mindanao. Petitioners then filed a petition for certiorari with the Supreme Court, requesting a preliminary injunction and/or restraining order to prevent the further proceedings against them. The Supreme Court granted the petition, stating that the complaint against petitioner-judge is administrative in nature and falls under the exclusive administrative supervision of the Supreme Court. The Office of the Ombudsman-Mindanao was directed to refer the complaint to the Supreme Court for appropriate action.

ISSUES

1. Whether the Office of the Ombudsman has jurisdiction to investigate complaints against a judge for alleged undue delay in the disposition of a criminal case, which is claimed to be an administrative matter.

RULING

The Supreme Court ruled that the Office of the Ombudsman does not have jurisdiction over the administrative complaint against the judge for undue delay in the disposition of a criminal case. The Court emphasized that the responsibility for overseeing the conduct of judges and ensuring they comply with the procedure falls exclusively under the Supreme Court. This administrative supervision includes the authority to investigate and decide on matters involving judicial conduct and ethics, as derived from the 1987 Constitution.

PRINCIPLES

1. Doctrine of Administrative Supervision Over Courts: The Supreme Court holds exclusive administrative supervision over all courts and court personnel, ensuring compliance with laws and taking appropriate administrative action for any violation.

2. Doctrine of Separation of Powers: No branch of government is allowed to intrude into the powers reserved for another branch, in this case, the judiciary, without violating the doctrine of separation of powers.

3. Preservation of Judicial Independence: Ensuring that the judiciary remains independent from the other branches of government, particularly in matters related to judicial conduct and discipline.