A.M. No. MTJ-11-1787; October 11, 2012
Office of the Court Administrator vs. Judge Marianito C. Santos, Metropolitan Trial Court, Branch 57, San Juan City

FACTS

This administrative case originated from Judge Marianito C. Santos’s request for an extension to decide two election protest cases. The Court granted a 30-day extension until June 7, 2008. Judge Santos submitted the decision for one case eight months beyond the extended period and required a further extension for the second, eventually deciding it in August 2009. The Office of the Court Administrator (OCA) subsequently conducted an audit and discovered that as of September 2010, Branch 57 had 304 cases submitted for decision, with 294 of these already beyond the reglementary period. Of the delayed cases, 143 were inherited from previous judges and 151 were submitted during Judge Santos’s own tenure.
In his defense, Judge Santos cited a heavy workload, additional duties as Executive Judge and Pairing Judge for another branch, and the need to monitor administrative and financial matters of the clerk of court’s office. He also argued that the cases were reflected in monthly reports and semestral docket inventories, implying the OCA was aware of the backlog. He later achieved full compliance by deciding all 294 backlogged cases.

ISSUE

Whether Judge Marianito C. Santos is administratively liable for undue delay in rendering decisions in 294 cases.

RULING

Yes, Judge Santos is administratively liable. The Court emphasized that the constitutional mandate to decide cases promptly is a paramount duty. Judges must organize their courts and manage their dockets to ensure compliance with reglementary periods. Heavy caseload, additional administrative duties, and demanding workload are not valid excuses for delay. The fact that the backlog was reported in court inventories does not mitigate the infraction; it merely confirms the existence of the delay. Full subsequent compliance with the directive to decide the cases does not exculpate a judge from administrative sanction, as the infraction had already been committed.
Undue delay in rendering a decision is a less serious charge under the Rules of Court. Considering the significant number of delayed cases (294), the Court found the maximum fine for a less serious charge to be appropriate. Judge Marianito C. Santos was found GUILTY of undue delay and ordered to pay a FINE of Twenty Thousand Pesos (P20,000.00). He was sternly warned that a repetition of the same infraction would be dealt with more severely.