AM MTJ 02 1449; (February, 2003) (Digest)
A.M. No. MTJ-02-1449. February 5, 2003. ENGR. FUNDADOR AMBALONG, complainant, vs. JUDGE ANTONIO C. LUBGUBAN, respondent.
FACTS
Complainant Engr. Fundador Ambalong was the plaintiff in Civil Case No. 311 for damages pending before the Metropolitan Circuit Trial Court of Siquijor, presided over by respondent Judge Antonio C. Lubguban. The case was submitted for decision upon the filing of complainant’s memorandum on January 5, 2000. The respondent judge, however, failed to render a decision within the constitutionally mandated 90-day period, which expired on April 5, 2000. The complainant filed this administrative complaint on March 14, 2001, alleging undue delay.
In his Comment, respondent judge admitted the delay. He explained that he had drafted the decision before the reglementary period lapsed but kept it in his cabinet for final editing. His attention was only called to the pending case in November 2000 by a staff member. He then finalized and rendered the decision on November 27, 2000. He attributed the oversight to a crowded docket and his additional duties in another sala. He claimed the decision was not served earlier due to an administrative lapse, with copies finally mailed on March 6, 2001.
ISSUE
Whether respondent Judge Antonio C. Lubguban is administratively liable for gross inefficiency due to his failure to decide Civil Case No. 311 within the 90-day reglementary period.
RULING
Yes, respondent judge is administratively liable for gross inefficiency. The 1987 Constitution and the Code of Judicial Conduct mandate that lower courts decide cases within three months from submission. The case was deemed submitted on January 5, 2000, making the deadline April 5, 2000. The decision rendered on November 27, 2000, was seven months late, constituting an unreasonable delay.
The Court rejected the judge’s justifications. A heavy caseload and assignment to another sala are not valid excuses for failing to comply with the constitutional deadline. The Court emphasized that judges must devise efficient court management systems to monitor cases due for decision. If unable to decide within the period, a judge must seek a timely extension from the Supreme Court, which respondent failed to do. His inaction, whether due to inadvertence or poor court management, directly contravenes the duty to administer justice promptly. Consequently, the Court imposed a fine of Five Thousand Pesos (P5,000.00) for gross inefficiency.