A.M. No. RTJ-12-2331, December 10, 2012
Marcelino A. Magdadaro vs. Judge Bienvenido R. Saniel, Jr.

FACTS

Complainant Marcelino Magdadaro filed an administrative complaint against respondent Judge Bienvenido Saniel, Jr. of the RTC, Branch 20, Cebu City, for undue delay, gross ignorance of the law, and bias/partiality concerning Civil Case No. CEB-27778, an action for breach of contract. The case stemmed from a dispute over the allegedly defective repair of complainant’s insured vehicle. After trial, complainant submitted his memorandum on November 11, 2008. Respondent judge rendered a decision dismissing the complaint on December 28, 2009, over one year later. Subsequently, complainant filed a notice of appeal on February 22, 2010, but the court acted upon it and transmitted the records only on December 2, 2010, a delay of nearly ten months.
Complainant alleged the delay in deciding the case and transmitting the records constituted unreasonable delay. He further accused respondent of gross ignorance for allegedly misappreciating insurance contract principles and of bias, claiming the decision contained misquoted testimony and relied on allegedly erroneous transcriptions. Respondent defended that the delay was due to heavy caseload and understaffing, and argued the administrative complaint was premature pending appeal.

ISSUE

Whether respondent judge is administratively liable for undue delay in rendering a decision and in transmitting case records to the appellate court.

RULING

Yes, respondent is administratively liable for undue delay. The Supreme Court found the delay of over one year in deciding the case from its submission for decision violated the constitutional mandate and the Code of Judicial Conduct requiring cases to be decided within 90 days. The Court rejected respondent’s justification of heavy caseload and understaffing, emphasizing that such circumstances do not excuse failure to comply with prescribed periods; judges must request extensions if necessary. Furthermore, the delay of almost ten months in acting on the notice of appeal and transmitting records was deemed unreasonable. The Court held that judges have the primary responsibility to supervise court personnel to ensure prompt dispatch of business.
The charges of gross ignorance of the law and bias were dismissed. Errors in judgment, if any, are not correctable administratively but through judicial appeals. Allegations of misquotation and reliance on transcripts pertain to the decision’s merits, not to bad faith or malice warranting administrative sanction. However, for the undue delays, which constitute a less serious charge under Rule 140, and considering respondent had a prior similar infraction, the Court imposed a fine of Fifteen Thousand Pesos (₱15,000.00).