A.M. No. RTJ-00-1602, December 5, 2000
Angel A. Gil, Complainant, vs. Judge Leoncio M. Janolo, Jr., Regional Trial Court, Branch 264, Pasig City, Respondent

FACTS

Complainant Angel A. Gil, a defendant in Civil Case No. 65268, filed an administrative complaint against Judge Leoncio M. Janolo, Jr. for failure to decide the said case within the constitutionally mandated 90-day period. The case was filed in August 1995. On April 14, 1998, respondent judge issued an order admitting the defendant’s formal offer of evidence and directed both parties to submit their memoranda in the form of a draft decision within 30 days, after which the case would be deemed submitted for decision. Both parties failed to comply. Consequently, on September 25, 1998, the judge issued another order reiterating the directive and giving the parties a final five-day period to file their memoranda, with a warning that failure to do so would be deemed a waiver.
By March 17, 1999, over five months after the September 1998 order and well beyond the 90-day reglementary period for deciding cases, the case remained undecided, prompting the complaint. In his Comment, respondent judge acknowledged the delay but attributed it to technical problems with his office computers. He explained that a decision had since been rendered after he personally bore the expense of solving the computer issues and that he had implemented a system to prevent future occurrences.

ISSUE

Whether respondent Judge Leoncio M. Janolo, Jr. is administratively liable for gross inefficiency for failing to decide Civil Case No. 65268 within the required period.

RULING

Yes, respondent judge is administratively liable. The Supreme Court found his excuse unsatisfactory. Article VIII, Section 15(1) of the Constitution mandates lower courts to decide cases within three months from submission. Rule 3.05, Canon 3 of the Code of Judicial Conduct reinforces this duty, requiring judges to dispose of court business promptly. The Court has consistently emphasized that failure to decide within the reglementary period constitutes gross inefficiency, as delay undermines public faith in the judiciary.
While the Court acknowledged that the computer problems cited by the judge were a mitigating factor and that the delay was not deliberate, this did not exonerate him from liability. The Court noted that cases can involve complex issues, and the 90-day period may sometimes be inadequate. The proper recourse in such situations, including when encountering technical difficulties, is to file a formal request for an extension of time from the Court. Respondent judge’s failure to seek an extension was a critical omission that rendered his delay inexcusable. The Court agreed with the Office of the Court Administrator’s recommendation and imposed a fine of Two Thousand Pesos (P2,000.00) with a stern warning against repetition.