AM 96 5 169 RTC; (May, 2003) (Digest)
A.M. No. 96-5-169-RTC; May 9, 2003
RE: REPORT ON THE JUDICIAL AUDIT CONDUCTED IN THE REGIONAL TRIAL COURTS OF KIDAPAWAN, BRANCHES 17 AND 23, KABACAN, BRANCHES 16 AND 17, NORTH COTABATO
FACTS
A judicial audit was conducted in the Regional Trial Court, Branch 17, Kidapawan City, presided by Judge Rodolfo Serrano. The audit revealed significant delays in the disposition of numerous cases. The Court required Judge Serrano to explain the delay in specific cases, including Criminal Cases Nos. 1644 and 2179 and Civil Case No. 0271. In his compliance, Judge Serrano explained that his court was designated as a special court for heinous crimes, making it physically impossible to promptly dispose of the inherited cases. A subsequent audit revealed an extensive list of unresolved cases and pending incidents, numbering over fifty, which remained undecided or unacted upon well beyond the reglementary periods.
ISSUE
Whether Judge Rodolfo Serrano and Branch Clerk of Court Gary V. Vergara are administratively liable for the findings of the judicial audit.
RULING
The Court absolved Branch Clerk of Court Gary V. Vergara. His explanation that any misreporting of a case status was due to inadvertence, not malice, was accepted. In the absence of bad faith, no administrative sanction was warranted.
The Court found Judge Rodolfo Serrano guilty of gross inefficiency. The Code of Judicial Conduct mandates judges to administer justice without delay and to dispose of court business promptly. The Court emphasized that inability to decide cases within required periods is not excusable and constitutes gross inefficiency, as it undermines public faith in the judiciary. While heavy caseloads may be considered, Judge Serrano failed to request a timely extension of time to decide the cases. His request was filed only after the Court’s intervention, more than a year after the reglementary period had lapsed. This infraction was aggravated by a lack of candor regarding case statuses and by the fact that he was a repeat offender, having been previously sanctioned in a separate administrative matter. Consequently, the Court deemed the Office of the Court Administrator’s recommended fine of P5,000.00 inadequate. Instead, a fine of Twenty Thousand Pesos (P20,000.00) was imposed as a more commensurate penalty for his gross inefficiency and failure to uphold the standards of judicial conduct.