G.R. No. A.M. No. MTJ-06-1639 ; July 28, 2006
BENITO MONCADA, complainant, vs. JUDGE ALDEN V. CERVANTES, MTC-Cabuyao, Laguna, respondent.

FACTS

Complainant Benito Moncada was the accused in Criminal Case No. 7079 for Usurpation of Real Property and Real Rights filed by the spouses Ebron on December 15, 2000, before the MTC of Cabuyao, Laguna, presided by respondent Judge Alden V. Cervantes. Moncada pleaded not guilty upon arraignment on May 24, 2001. The case, governed by the Rule on Summary Procedure, subsequently experienced multiple postponements of pre-trial. Moncada filed several motions, including a Motion to Suspend Action (denied July 29, 2002) and two Motions to Dismiss (denied February 16, 2004, and July 7, 2004), all of which were resolved by the respondent judge. The criminal case remained unresolved and pending for over five years, from May 2001 to at least January 2006.
Moncada filed the present administrative complaint on November 24, 2005, charging respondent judge with undue delay in resolving the criminal case and with violations of the Code of Judicial Conduct. He alleged that no transcript of stenographic notes (TSNs) had been prepared. Respondent judge retired from the judiciary on November 23, 2005, a day before the complaint was filed. In his defense, he filed a Manifestation and Motion to Dismiss, asserting the complaint was baseless and that his denials of the motions were exercises of sound judicial discretion.

ISSUE

Whether respondent Judge Alden V. Cervantes is administratively liable for undue delay in resolving Criminal Case No. 7079.

RULING

Yes, respondent judge is administratively liable for undue delay. The Office of the Court Administrator (OCA) correctly found the charge of ignorance of the law for denying the motions to dismiss unmeritorious, as those were judicial acts reviewable by appeal. However, the OCA found respondent judge remiss in his duty to resolve the criminal case with dispatch, violating Canon 3, Rule 3.05 of the Code of Judicial Conduct and the constitutional right to a speedy disposition of cases.
The Court emphasized that judges have a sworn duty to administer justice promptly. Delay in any case, regardless of its perceived significance, constitutes a delay in the administration of justice itself and undermines public trust. The protracted pendency of the summary case for over five years, without a valid justification from the respondent judge, constitutes gross inefficiency. His retirement from service does not preclude administrative liability, as the infraction occurred during his incumbency. The Court adopted the OCA’s recommendation, imposing a fine of Twenty Thousand Pesos (P20,000.00) to be deducted from his retirement benefits, commensurate with the less serious charge of undue delay under the rules.