A.M. No. 94-5-42-MTC. March 20, 1996. QUERY OF JUDGE DANILO M. TENERIFE, MTC, PONTEVEDRA, NEGROS OCC. AS TO WHO SHOULD DECIDE THE CASES SUBMITTED FOR DECISION IN SAID COURT.
FACTS:

Judge Danilo M. Tenerife, upon assuming office as Acting Judge of the MTCC, Branch II, Bacolod City, conducted a physical inventory and discovered 82 cases submitted for decision but left undecided by his predecessor, Judge Demosthenes L. Magallanes. Judge Tenerife inquired with the Office of the Court Administrator (OCA) as to who should decide these cases. The Court initially resolved that the cases be raffled among the MTCC branches in Bacolod City and directed Judge Magallanes to explain his failure to decide them within the 90-day reglementary period.
Judge Magallanes explained that the delay was due to the frequent illness and failure of his court stenographers to complete the transcripts of stenographic notes (TSN). He reported reducing the number of undecided cases to 73 with the assistance of a pairing judge after TSN completion and expressed deep regret, requesting permission to decide the remaining cases himself to avoid burdening his successor, a request denied by court administrators.

ISSUE

Whether Judge Demosthenes L. Magallanes is administratively liable for his failure to decide the 82 (later 73) cases within the mandatory 90-day period.

RULING

Yes, Judge Magallanes is guilty of gross inefficiency. The Court emphasized that Canon 3, Rule 3.05 of the Code of Judicial Conduct mandates judges to dispose of court business promptly and decide cases within 90 days from submission. Failure to comply is inexcusable and constitutes gross inefficiency, undermining public confidence in the judiciary.
The Court rejected Judge Magallanes’s explanation attributing the delay to his stenographers’ failure to transcribe notes. A judge cannot shift blame to court personnel for his own negligence. Judges are required to take notes during hearings and can prepare decisions without awaiting full transcripts; the 90-day period is mandatory regardless of transcription status. The Court noted the imperative to minimize court congestion and delay, stating that justice delayed is justice denied.
Considering the substantial number of undecided cases, the Court found the OCA’s recommended fine of P5,000.00 insufficient. While treating this as a first offense mitigating the penalty, the Court increased the fine to P10,000.00 to reflect the seriousness of the violation. Judge Magallanes was ordered to pay the fine directly to the Supreme Court with a stern warning against repetition.