AM 09 9 163 MTC; (May, 2010) (Digest)
A.M. No. 09-9-163-MTC; May 6, 2010
RE: CASES SUBMITTED FOR DECISION BEFORE HON. TERESITO A. ANDOY, former Judge, Municipal Trial Court, Cainta, Rizal.
FACTS
This administrative matter arose from the request for a Certificate of Clearance by compulsorily retired Judge Teresito A. Andoy of the Municipal Trial Court (MTC) of Cainta, Rizal, to facilitate the release of his retirement and other monetary benefits. Judge Andoy admitted to having unaccounted property accountabilities and a pending administrative case, expressing willingness to have any penalty deducted from his benefits. A judicial audit, however, revealed that during his tenure, Judge Andoy failed to decide 139 cases within the constitutionally mandated reglementary period. Some of these cases had been submitted for decision as early as 1997. The Office of the Court Administrator (OCA) recommended that a fine of Seventy Thousand Pesos (₱70,000.00) be imposed for gross inefficiency and deducted from his benefits.
ISSUE
Whether retired Judge Teresito A. Andoy should be held administratively liable for his failure to decide the 139 cases within the reglementary period, and if so, what is the appropriate penalty.
RULING
Yes, Judge Andoy is administratively liable for gross inefficiency. The Court emphasized that Article VIII, Section 15(1) of the 1987 Constitution and the Code of Judicial Conduct mandate judges to decide cases within 90 days from submission. This rule is indispensable to prevent needless delays and to uphold the people’s faith in the judiciary. Delay deprives parties of their right to a speedy disposition of their cases. The Court found Judge Andoy’s inefficiency evident, as he offered no valid explanation for the delay and did not request extensions from the Court, which are typically granted given heavy caseloads.
Regarding the penalty, the Court modified the OCA’s recommendation. Under the amended Rule 140 of the Rules of Court, undue delay in rendering a decision is a less serious charge punishable by a fine of more than ₱10,000.00 but not exceeding ₱20,000.00. The Court considered the staggering number of 139 undecided cases as a severe aggravating circumstance. While past precedents showed fines ranging from ₱10,000.00 to ₱20,000.00 for a far smaller number of cases, the extreme volume here warranted a significantly higher fine to reflect the gravity of the neglect. Consequently, the Court imposed a fine of Two Hundred Thousand Pesos (₱200,000.00), to be deducted from his retirement benefits, holding that such an amount is commensurate to the magnitude of his failure to fulfill a fundamental judicial duty.