G.R. No. A.M. No. MTJ-00-1322. July 17, 2001
RENATO H. SANCHEZ, complainant, vs. JUDGE GEMINIANO A. EDUARDO, respondent.

FACTS

Complainant Renato H. Sanchez filed an administrative complaint against respondent Judge Geminiano A. Eduardo, then Presiding Judge of the Municipal Trial Court of Peñaranda, Nueva Ecija, for serious misconduct and gross inefficiency. The complaint stemmed from the judge’s handling of Election Protest Case No. 001-97, entitled “Renato H. Sanchez vs. Conrado H. Aberin,” filed on May 22, 1997. The protest was dismissed by the respondent judge via a Resolution dated November 6, 1997. Complainant filed a Motion for Reconsideration on November 17, 1997. The respondent judge issued an Order on April 16, 1998, deeming the motion submitted for resolution. However, the motion remained unresolved for about a year from its submission, violating the 90-day period for resolving motions and the specific 15-day mandate under the Omnibus Election Code for deciding barangay election protests. The complainant alleged this delay constituted a violation of his right to a speedy disposition of his case and implied the judge submitted falsified certificates of service. In his defense, the respondent judge admitted the delay but explained that the parties had intimated a pending settlement, and he had advised them to file the necessary pleadings, which they did not do. He also cited his various court assignments, heavy workload, mental lapses due to age, and the frailty of human memory.

ISSUE

Whether respondent Judge Geminiano A. Eduardo is administratively liable for gross inefficiency due to his failure to resolve the Motion for Reconsideration in the election protest case within the reglementary period.

RULING

Yes, the respondent judge is administratively liable for gross inefficiency. The Supreme Court found his explanations for the delay unpersuasive. The alleged settlement was belied by the complainant’s vigorous pursuit of the case. A heavy workload is not a sufficient excuse for failing to decide cases within the required period; judges must request an extension from the Court if needed. The failure to decide an election protest promptly, especially given the public interest and the short term of barangay officials, constitutes gross inefficiency. Judges are mandated to dispose of court business promptly. Delay in case resolution is a delay of justice. Accordingly, the Court found Judge Geminiano A. Eduardo liable and ordered him to pay a fine of Five Thousand Pesos (P5,000.00) with a warning that future similar acts would be dealt with more severely.