Name: Dela Cruz, Mary Julieanne D.R.

Section: JD-1D
Constitutional Law 01 | Case Digest
Doctrine: Judicial Department, Supreme Court of the Philippines –Disciplinary Powers
Case Title: People of the Philippines vs. Eustaquio Z. Gacott, Jr., et al., G.R. No. 116049, July
13, 1995
Facts:
In a reconsideration of a judgement of a criminal case, Judge Eustaquio Gacott assails that the
only issue that is to be resolved is whether or not he abused his discretion in granting the motion
to quash the aforementioned case. However, for failure to check the citations of the prosecution,
the order of Judge Gacott, Jr. dismissing a criminal case was annulled by the SC. The respondent
judge was also sanctioned with a reprimand and a fine of P10,000.00 for gross ignorance of the
law. The judgment was made by the Second Division of the SC. Thus, leading to Gacott
questioning whether the Second Division of the Supreme Court had the power to
administratively discipline him.
Issue: Whether or not the Supreme Court has the power to discipline trial court judges.
Ruling:
YES. The Supreme Court possesses the power to discipline judges of lower courts, as encased in
the first clause of Section 11 of Article VIII of the Constitution. However, this does not mean that
the intention of the authors of the Constitution was to have all administrative disciplinary cases
be heard and decided by the Supreme Court as doing so would result in absurdity. Pursuant to the
aforementioned clause, a decision en banc is only needed where the penalty to be imposed is the
dismissal of a judge, officer or employee of the Judiciary, disbarment if a lawyer, or either the
suspension of any of them for a period of more than one (1) year or a fine exceeding Ten
Thousand Pesos (Php10,000.00) or both. To require the Supreme Court to deliberate and
participate in all administrative matters or cases regardless of the sanctions, imposable or
imposed, would result in a congested docket and due delay in the resolution of cases handled by
the Court, especially in administrative matters, since even cases involving the penalty of
reprimand would require action by the Court en banc.