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JurisprudenceA.M. No. MTJ-25-051

A.M. No. MTJ-25-051 (Formerly JIB FPI No. 24-159-MTJ) - OFFICE OF THE COURT ADMINISTRATOR, COMPLAINANT, VS. HON. WILFREDO G. OCA, PRESIDING JUDGE, MUNICIPAL TRIAL COURT, REAL, QUEZON.

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accordingly FINED in the amount of PHP 200,000.00 for each count of gross neglect of duty, for a total aggregate of fines in the amount of PHP 400,000.00; 3) Respondent former Judge Oca be DIRECTED to PAY the fines imposed within a period not exceeding three [ ] months from the time of promulgation of this Decision. If unpaid within the required period, the fines imposed be deducted from his retirement benefits, including accrued leave credits; 4) The instant matter be also TREATED and DOCKETED as a complaint against respondent Judge Oca as a member of the Philippine Bar; and 5) Respondent former Judge Oca, as a member of the Philippine Bar, be found GUILTY of gross neglect of duty under the Code of Professional Responsibility and Accountability and accordingly SUSPENDED from the practice of law for a period of one [ ] year. [26] (Emphasis in the original) In finding Judge Oca liable for Gross Neglect of Duty, Executive Director Tolentino noted that the delays, ranging from five months to over 15 years, violated the New Code of Judicial Conduct [27] and constituted negligence under Rule 140, as amended by Administrative Matter No. 21-08-09-SC. [28] Given the extent and frequency of the delays, the offense was deemed gross. [29] Citing Office of the Court Administrator v. Judge Balo , [30] Executive Director Tolentino held that separate findings of gross neglect were warranted because the duties involved different laws or rules: one count pertained to criminal cases, and the other to civil cases. [31] He recommended a penalty of PHP 200,000.00 for each count, considering Judge Oca's prior administrative sanctions. [32] Additionally, Executive Director Tolentino recommended that Judge Oca be held liable as a member of the Philippine Bar. [33] Pursuant to Canon VI, Section 33(d) of the Code of Professional Responsibility and Accountability, which treats gross negligence in the performance of duty as a serious offense, Executive Director Tolentino deemed suspension from the practice of law as an appropriate penalty. [34] The Recommendation of the JIB In a Resolution, [35] dated April 28, 2025, the JIB resolved to adopt the Report and recommendation of the JIB-OED. The Issues 1. Should Judge Oca be held administratively liable for his failure to resolve cases within the reglementary period? 2. Should Judge Oca be also disciplined as a member of the Philippine Bar for his delay in resolving 62 cases? The Ruling of the Court The Court finds Judge Oca administratively liable for gross neglect of duty. However, his act does not warrant an imposition of a penalty as a member of the Philippine Bar. The Court has administrative jurisdiction over Judge Oca, notwithstanding his mandatory retirement on June 25, 2024 Preliminarily, the Court deems it proper to discuss whether the Court retains jurisdiction over Judge Oca, despite his compulsory retirement on June 25, 2024. An administrative proceeding against a member of the judiciary may only be instituted duri