A.M. No. RTJ-10-2248. September 29, 2010.
JUDGE ADORACION G. ANGELES, Complainant, vs. JUDGE MARIA ELISA SEMPIO DIY, Respondent.

FACTS

Complainant Judge Adoracion G. Angeles, the private complainant in two consolidated criminal cases, filed an administrative complaint against respondent Judge Maria Elisa Sempio Diy for undue delay in rendering judgment and resolving a pending motion. The cases were submitted for decision on June 20, 2008, with promulgation initially set for September 11, 2008. Respondent judge, however, requested three extensions, resetting the promulgation multiple times citing a medical consultation, voluminous records, and attendance at an overseas symposium. The Joint Decision was finally promulgated on December 12, 2008, six months after submission. Complainant alleged the decision was rendered beyond the 90-day constitutional period and that no proof of granted extensions existed in the case records. Furthermore, after one convicted accused filed an Urgent Motion for Reconsideration in January 2009, respondent judge waited over six months before issuing an order submitting it for resolution in July 2009, and then denied it in August 2009. Complainant argued this constituted another instance of unjustifiable delay.

ISSUE

Whether respondent Judge Maria Elisa Sempio Diy is administratively liable for undue delay in rendering the Joint Decision and in resolving the pending Urgent Motion for Reconsideration.

RULING

Yes, respondent judge is administratively liable. The Supreme Court found that while respondent judge had indeed requested extensions from the Court, which were granted, her failure to decide the case within the extended period granted by the last resolution constituted a violation. The Court emphasized that requests for extension do not excuse a judge from liability if they still fail to decide within the extended period. The constitutional mandate to decide cases within three months is mandatory. The Court also found undue delay in resolving the motion for reconsideration. The prosecution filed its opposition in January 2009, yet respondent judge only acted to submit it for resolution in July 2009, without a clear justification for the six-month interval. This delay violated the rules on prompt disposition of court business. The Court held that judges must dispose of the court’s business promptly and decide cases within required periods. Failure to do so constitutes gross inefficiency, which undermines public confidence in the judiciary. Considering the delays in both instances, respondent was found guilty of gross inefficiency and fined P40,000, with a stern warning.