A.M. No. RTJ-04-1867; February 17, 2005
Metchier Belleza and Arsenio Belleza, complainants, vs. Judge Benedicto Cobarde, Presiding Judge of the Regional Trial Court, Br. 53, Lapu-Lapu City, Respondent.

FACTS

Complainants Metchier and Arsenio Belleza charged respondent Judge Benedicto G. Cobarde with undue delay in rendering judgment in a special proceedings case for the settlement of an estate. The case was submitted for decision as early as January 21, 1998, but for almost five years, the judge took no action. The complainants alleged this delay deprived them of their rightful shares in their brother’s estate. They further accused the judge of collusion with the oppositor, Lugenita Belleza, and questioned his refusal to inhibit himself from the case despite their dissatisfaction with the inaction.
In his Comment, Judge Cobarde did not deny the delay and offered no justification for it. He apologized to the parties and manifested that he had already rendered a decision on the case. However, he vehemently denied any collusion with any party, stating he had never been biased in his ten years of service. The Office of the Court Administrator (OCA) investigated and found the judge liable for undue delay and neglect of duty, recommending a fine of Ten Thousand Pesos (₱10,000).

ISSUE

Whether respondent Judge Benedicto G. Cobarde is administratively liable for undue delay in rendering a decision.

RULING

Yes, the Supreme Court found Judge Cobarde administratively liable. The Court emphasized that while it recognizes the heavy caseloads of judges, they are not excused from their constitutional and statutory duty to decide cases within the reglementary period. The 1987 Constitution mandates lower court judges to decide cases within 90 days, and the Code of Judicial Conduct directs judges to dispose of court business promptly. Any delay undermines public faith in the judiciary and deprives litigants of their right to a speedy disposition.
The Court noted that while it may grant reasonable extensions, judges cannot unilaterally extend the period. Here, Judge Cobarde not only failed to decide the case for nearly five years but also did not request any extension from the Court or offer any valid excuse for the delay. His indifference constituted a mockery of the laws he swore to uphold. Under Section 9(1), Rule 140 of the Revised Rules of Court, undue delay is a less serious charge. While agreeing with the OCA’s finding of liability, the Court deemed the recommended fine of ₱10,000 insufficient for an unjustified five-year delay. Accordingly, the Court imposed a fine of Fifteen Thousand Pesos (₱15,000) with a stern warning against repetition.