Case Parties:
RE: REPORT ON THE JUDICIAL AUDIT CONDUCTED IN THE RTC-BRANCH 220, QUEZON CITY. Judge Prudencio Altre Castillo, Respondent.
FACTS
1. A judicial audit was conducted in the Regional Trial Court of Quezon City, Branch 220, upon the compulsory retirement of its Presiding Judge, Prudencio Altre Castillo, on February 18, 2000.
2. The audit revealed that Branch 220 had a total caseload of 426 cases. Among these, thirty-five (35) cases were submitted for decision, with fifteen (15) undecided beyond the 90-day reglementary period. Seven (7) incidents in other cases were pending resolution, and no further action had been taken on five (5) civil cases for a considerable time.
3. It was also reported that Judge Castillo set two criminal cases for promulgation of judgment on his retirement date, and the decisions penned by him were read in open court.
4. The Court required Judge Castillo to explain his failure to decide the cases and resolve the incidents within the reglementary period. It also recalled the judgments he promulgated on his retirement date in Criminal Case Nos. 93-44537 and Q-98-76558, directing Acting Presiding Judge Jose Catral Mendoza to issue appropriate decisions for said cases.
5. In his explanation, Judge Castillo cited serious health issues, including major surgical operations for colon cancer (November 14, 1994) and urinary bladder cancer (March 22, 1997), supported by medical records. He stated he reported for work while undergoing therapy against medical advice. He also mentioned the emotionally draining experience of three family members (a brother, a sister, and his mother) succumbing to cancer in the year prior to his retirement, requiring him to handle their wakes and burials.
6. Acting Presiding Judge Mendoza filed a manifestation, stating he could not comply with the Court’s directive regarding Criminal Case No. Q-93-44537 because the Court of Appeals had temporarily enjoined him from proceeding due to a pending Petition for Certiorari (G.R. SP No. 57324).
7. The Office of the Court Administrator (OCA) recommended that Judge Castillo be fined Ten Thousand Pesos (P10,000.00), deductible from his retirement benefits, for his failure to decide and act upon the cases. It also recommended that Judge Mendoza hold in abeyance the implementation of the Court’s resolution regarding Criminal Case No. Q-93-44537 pending the Court of Appeals’ resolution.
ISSUE
Whether Judge Prudencio Altre Castillo is administratively liable for his failure to decide cases and resolve incidents within the reglementary period, and if so, what is the appropriate penalty considering his explanations.
RULING
1. Judge Castillo is administratively liable for delay and neglect of duty. The Court found his reasons (serious ailment and family tragedies) insufficient to completely excuse his failure. While his condition hampered his performance, it was incumbent upon him to inform the Court of his inability and to request an extension of time for the disposition of the cases. His neglect in this regard cannot be completely excused. The failure to decide cases within the periods fixed by law constitutes neglect of duty, which erodes public faith in the judiciary.
2. The recommended fine is reduced on humanitarian grounds. The Court considered the OCA’s recommendation to treat Judge Castillo’s medical condition and failing health as mitigating circumstances. While a fine is the appropriate penalty, the Court reduced the OCA’s recommended fine of Ten Thousand Pesos (P10,000.00) to Five Thousand Pesos (P5,000.00) as a disciplinary sanction.
3. Disposition: Judge Prudencio Altre Castillo is FINED Five Thousand Pesos (P5,000.00), to be deducted from his retirement benefits. Acting Presiding Judge Jose Catral Mendoza is directed to HOLD IN ABEYANCE the implementation of the Court’s earlier resolution regarding Criminal Case No. Q-93-44537 until the Court of Appeals resolves G.R. SP No. 57324. A copy of the resolution is to be forwarded to the OCA for the release of Judge Castillo’s remaining benefits and to the Court of Appeals for its information.
