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Magdadaro v.

Saniel
A.M. No. RTJ-12-2331; December 10, 2012
Facts:
Petitioner Magdadaro filed an action for breach of contract with damages on May 30, 2002 that
was raffled to Regional Trial Court, Branch 20 of Cebu City.
Said case was presided over by respondent Judge Bienvenido Saniel
Respondent then rendered a decision on December 28, 2009 dismissing the complaint for lack of
cause of action
Petitioner then filed a Notice of Appeal on February 22, 2010 which was acted only by said court
on December 2, 2010
Frustrated with how the court is handling the case, Petitioner filed this administrative complaint
alleging unreasonable delay on the Civil Case that took more thank one year to be decided.
Complainant also asserts that respondent was ignorant of the law when respondent did not know
the respective liabilities and obligations of the parties.
In addition, petitioner claims that there was partiality on the part of the Judge in the said Civil
Case citing questions and answers not correctly transcribed and certain statements, which
defendants did not actually say.
Respondent counters by stating that gross ignorance cannot be yet determined as the appellate
court has yet to affirm his ruling.
In addition, Respondent argues that his court was undermanned that led to the delay.
CRIMINAL LAW
Issue: WON Respondents decision in the Civil Case was illegal and was rendered with no basis in fact
and law.
Held/Ratio: No. In Salvador v. Limsiaco, Jr., it was stated that only judicial errors tainted with fraud,
dishonesty, gross ignorance, bad faith or deliberate intent to do an injustice will be administratively
sanctioned. In this case, there is no showing that respondent was motivated by bad faith or ill motive in
deciding the case. Furthermore, records show that complainant already filed an appeal before the Court of
appeals. An administrative complaint cannot be pursued while seeking judicial remedies nor are they
alternatives available to an aggrieved party as discussed extensively in Flores v. Abesamis.
Issue: WON Respondent is guilty of undue delay in deciding Civil Case No. CEB-27778 and in
answering the Notice of Appeal filed by complainant.
Held/Ratio: Yes. Citing Article 15(1), Article VIII of the Constitution, that mandates cases or matters
filed to lower court should be resolved within three months from the date they are submitted. Judges
should decide cases promptly and expeditiously for justice delayed is justice denied. This is important, as
delay would undermine the peoples faith and confidence to the judiciary. Respondent failed to live up to
these standards.