G.R. No.: A.M. No. RTJ-14-2385 (Formerly A.M. No. 14-4-115-RTC)
Date: April 20, 2016

Case Parties/Title: Office of the Court Administrator, Petitioner, vs. Judge Romeo B. Casalan, Respondent.

FACTS

This administrative case arose from a judicial audit conducted on August 7-8, 2012, in the Regional Trial Court (RTC) of Culasi, Antique, Branch 13 (Judge Casalan’s regular court) and the RTC of Bugasong, Antique, Branch 65 (where he was the acting presiding judge). The audit revealed significant delays and administrative deficiencies. In Branch 13, findings included: 48 cases submitted for decision beyond the 90-day reglementary period; 29 cases with pending motions/incidents unresolved beyond the mandatory period; 19 dormant cases; 10 cases pending for 10 years or more; and poor case record management. In Branch 65, findings included: 2 cases submitted for decision beyond the period; 14 cases with unresolved motions; 22 dormant cases; and similar record-keeping issues. The Office of the Court Administrator (OCA) directed Judge Casalan to explain the delays, decide/resolve the pending matters, and correct the administrative lapses. Judge Casalan requested a two-month extension but subsequently failed to comply with the OCA’s repeated directives, even after a warning that administrative charges would be filed. He reached mandatory retirement on March 2, 2014, without having complied.

ISSUE

Whether Judge Romeo B. Casalan is administratively liable for undue delay in the disposition of cases and for insubordination due to his failure to comply with the lawful directives of the Office of the Court Administrator.

RULING

Yes, Judge Casalan is administratively liable. The Supreme Court adopted the OCA’s recommendation and found him guilty of undue delay in rendering decisions/orders (a less serious charge under Section 9[1], Rule 140 of the Rules of Court) and of insubordination. The Court emphasized that the rules on periods for deciding cases are mandatory. Delay deprives litigants of their constitutional right to a speedy disposition of cases, erodes public faith in the judiciary, and invites suspicion. While the Court noted that Judge Casalan had been presiding over two courts and handling inhibited cases from other branches, this did not exonerate him; he should have requested an extension of time or relief from additional designations if he could not manage the workload. His outright refusal to obey the OCA’s directives constituted insubordination and disrespect to the Court’s authority. Consequently, the Court imposed a fine equivalent to three (3) months of his salary at the time of retirement, to be deducted from his retirement/gratuity benefits.