A.M. No. 00-8-05-SC; January 31, 2002
RE: PROBLEM OF DELAYS IN CASES BEFORE THE SANDIGANBAYAN

FACTS

This administrative matter originated from an Integrated Bar of the Philippines (IBP) resolution recommending an inquiry into the causes of delay in the Sandiganbayan. The Supreme Court required Sandiganbayan Presiding Justice Francis E. Garchitorena to comment and submit a list of pending cases. The data revealed a severe backlog, with 415 cases submitted for decision but undecided as of September 2000. The First Division, chaired by PJ Garchitorena, accounted for 341 of these delayed cases, some pending for up to ten years. An audit also found administrative deficiencies in the court’s recording system, a responsibility under the Presiding Justice’s control.
Following its inquiry, the Court, in a Resolution dated November 28, 2001, found PJ Garchitorena administratively liable for inefficiency and gross neglect of duty. It imposed a P20,000 fine, temporarily relieved him of his administrative duties and role in presiding over trials, and ordered him to focus exclusively on deciding the backlog in his division, including numerous unassigned cases. PJ Garchitorena filed a motion for reconsideration, arguing he was denied due process and equal protection, as he was not formally charged nor given an opportunity to explain the specific allegations before the sanction was imposed.

ISSUE

Whether Presiding Justice Garchitorena was denied due process in the administrative proceedings against him.

RULING

The Supreme Court DENIED the motion for reconsideration, holding that PJ Garchitorena was not denied due process. The legal logic is that due process in administrative proceedings, especially against judges, is satisfied by an opportunity to be heard, not necessarily a formal trial-type hearing. The Court found this opportunity was amply provided. PJ Garchitorena himself filed the compliance that detailed the Sandiganbayan’s backlog, which incriminated him. He also wrote a letter to the Chief Justice admitting the backlog. The audit conducted by the Office of the Court Administrator was based on reports from the Sandiganbayan itself, which he heads.
The Court emphasized that a judge is always on notice that delay in deciding cases constitutes a ground for administrative sanction. The IBP resolution, which triggered the Court’s inquiry, squarely involved the problem of delays attributable to the Sandiganbayan’s leadership. PJ Garchitorena, as Presiding Justice and Division Chairman, bore responsibility for the massive backlog in his court, particularly in his own division. His claim of being singled out was unfounded, as the sanction was directly proportional to the gravity of the inefficiency under his watch. The penalty was upheld as a necessary measure to address the severe impairment of the right to a speedy disposition of cases, a fundamental constitutional right.