AM MTJ 06 1653; (July, 2007) (Digest)
A.M. No. MTJ-06-1653; July 30, 2007
Eugenio Juan R. Gonzalez vs. Judge Lizabeth G. Torres, Metropolitan Trial Court, Branch 60, Mandaluyong City
FACTS
Complainant Eugenio Juan R. Gonzalez charged Judge Lizabeth G. Torres with undue delay in resolving a Demurrer to Evidence in Criminal Case No. 71984 for perjury. The demurrer was submitted for resolution on June 20, 2002. By October 2003, a certification from the Branch Clerk of Court confirmed the matter remained unresolved. Gonzalez sought Judge Torres’s inhibition from the case. In the administrative proceedings, the Office of the Court Administrator (OCA) required Judge Torres to comment. She requested and was granted multiple extensions over two years, finally submitting her comment in February 2006.
In her defense, Judge Torres claimed the case records were disorganized, “rigged,” and contained dubious pleadings and orders. She asserted she had no official intervention since May 2002 and inhibited herself to avoid being drawn into the underlying property dispute. She cited her heavy caseload, additional duties as Executive Judge, and staff vacancies as reasons for the delay in both the case resolution and her administrative comment.
ISSUE
Whether Judge Lizabeth G. Torres is administratively liable for undue delay in resolving the Demurrer to Evidence.
RULING
Yes, Judge Torres is administratively liable. The Court found her guilty of undue delay and imposed a fine of Twenty Thousand Pesos (₱20,000.00). The legal logic is anchored on the constitutional mandate and the Code of Judicial Conduct requiring judges to dispose of court business promptly. Delay in resolving pending motions or incidents within the prescribed period constitutes a violation of these rules. Judge Torres’s justifications were deemed insufficient. Administrative convenience, such as disorganized records or heavy workload, does not excuse failure to perform a judicial duty. Judges must devise efficient systems to manage their caseloads. Her inhibition from the case, if valid, did not absolve her of the duty to resolve the pending demurrer before inhibiting; she should have resolved it first. Furthermore, her protracted delay in submitting her required comment to the OCA, despite several extensions, demonstrated a disregard for lawful directives and exacerbated her administrative culpability. The fine serves as a sanction for violating the duty of diligence and promptness.