AM 99 1 01 RTC; (January, 2003) (Digest)
A.M. No. 99-1-01-RTC; January 20, 2003
RE: CASES LEFT UNDECIDED BY RETIRED JUDGE ANTONIO E. ARBIS, REGIONAL TRIAL COURT, BRANCH 48, BACOLOD CITY.
FACTS
Judge Antonio E. Arbis compulsorily retired on June 13, 1998. A subsequent judicial audit revealed two categories of problematic cases. First, he decided seventeen cases but only signed the decisions two days before retirement, with promulgation occurring after his retirement, rendering them invalid. Second, he failed to decide numerous criminal and civil cases within the 90-day reglementary period. When required to comment, Judge Arbis offered various explanations, primarily that several case records were not submitted to him by the Clerk of Court, some cases were not listed in monthly reports as submitted for decision, and transcripts were received only after his retirement. He claimed these cases were thus not brought to his attention.
ISSUE
Whether Judge Antonio E. Arbis is administratively liable for undue delay in rendering decisions.
RULING
Yes, Judge Arbis is administratively liable. The Court emphasized the constitutional mandate and the Code of Judicial Conduct requirement for judges to decide cases within three months from submission. Undue delay constitutes gross inefficiency and denies justice, eroding public confidence in the judiciary. The Court rejected Judge Arbis’s excuses. The primary responsibility for case inventory and docket management rests with the presiding judge under Rule 3.09, Canon 3 of the Code of Judicial Conduct. A judge must devise an efficient system to monitor cases and cannot shift blame to court personnel for mismanagement. Proper court administration is the judge’s non-delegable duty; court personnel are not guardians of a judge’s responsibilities. His failure to decide the enumerated cases within the period, some of which were submitted for years, demonstrated a lack of reasonable dispatch. The offense is a less serious charge under the Revised Rules of Court. Considering his retirement, the Court imposed a fine of Twenty Thousand Pesos (P20,000.00), to be deducted from his withheld retirement benefits.