Petitioner contends that the “indecent and precipitate haste” of public respondent in finding the two complaints sufficient in form and substance is a clear indication of bias, she pointing out that it only took public respondent five minutes to arrive thereat.
An abbreviated pace in the conduct of proceedings is not per se an indication of bias, however. So Santos-Concio v. Department of Justice[31] holds:
Speed in the conduct of proceedings by a judicial or quasi-judicial officer cannot per se be instantly attributed to an injudicious performance of functions. For one’s prompt dispatch may be another’s undue haste. The orderly administration of justice remains as the paramount and constant consideration, with particular regard of the circumstances peculiar to each case.
The presumption of regularity includes the public officer’s official actuations in all phases of work. Consistent with such presumption, it was incumbent upon petitioners to present contradictory evidence other than a mere tallying of days or numerical calculation. This, petitioners failed to discharge. The swift completion of the Investigating Panel’s initial task cannot be relegated as shoddy or shady without discounting the presumably regular performance of not just one but five state prosecutors.[32] (italics in the original; emphasis and underscoring supplied)
http://sc.judiciary.gov.ph/jurisprudence/2011/february2011/193459.htm
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