AM 00 3 14 SC; (October, 2002) (Digest)
G.R. No. A.M. No. 00-3-14-SC October 4, 2002
RE: LIST OF JUDGES WHO FAILED TO COMPLY WITH ADMINISTRATIVE CIRCULAR NO. 10-94, DATED JUNE 29, 1994.
FACTS
The Court Administrator submitted a list of 57 judges who failed to comply with Administrative Circular (AC) No. 10-94, which requires trial judges to submit a semestral tabulation of all pending cases and certify a personal inventory. The Circular mandates submission by the last week of February and August each year, with wilful non-compliance constituting serious misconduct. The Court directed the judges to explain why no administrative sanction should be imposed and ordered the withholding of their salary checks. Of the 57, 4 submitted the required inventory, while 53 complied with the explanation directive. The judges’ explanations were categorized by the OCA: heavy caseloads/holding multiple salas; official leave during submission period; lack of manpower due to vacancies or leaves of court personnel; poor supervision or oversight; denial of knowledge of the Circular; and admission of failure without explanation. Specific judges, such as Judge Tan of RTC Balaoan, La Union, provided explanations involving alleged staff absences, but investigations revealed discrepancies in daily time records, suggesting possible falsification.
ISSUE
Whether the judges who failed to comply with Administrative Circular No. 10-94 should be held administratively liable.
RULING
Yes. Judges are administratively liable for non-compliance with Supreme Court administrative circulars. The primary responsibility for the proper functioning of a court rests with the judge, who cannot evade liability by blaming court personnel. Administrative Circular No. 10-94 is designed to promote efficient administration of justice, and compliance is a mandatory duty. The Court imposed fines on the erring judges, with amounts varying based on the circumstances and explanations provided. For instance, judges who cited heavy caseloads, official leave, or lack of manpower were fined P1,000 each. Judges who admitted poor supervision or oversight were fined P2,000 each. Judges who denied knowledge of the Circular were fined P3,000 each, as ignorance of a circular already in effect for years is inexcusable. Judges who admitted failure but gave no explanation were fined P5,000 each. The Court emphasized that judges must diligently oversee court operations and ensure strict adherence to administrative requirements, as these are integral to the prompt delivery of justice.