AM 01 2 47 RTC; (August, 2001) (Digest)
A.M. No. 01-2-47-RTC August 9, 2001
RE: REPORT ON THE JUDICIAL AUDIT CONDUCTED IN THE RTC-BR. 26, MANILA, PRESIDED BY JUDGE GUILLERMO L. LOJA
FACTS
A judicial audit was conducted on the Regional Trial Court, Branch 26, Manila, prior to the compulsory retirement of Presiding Judge Guillermo L. Loja. The audit team found the court properly managed but identified twenty-four civil cases submitted for decision beyond the reglementary period and nineteen cases unacted upon for a considerable time. The Court required Judge Loja to explain the delays. In his compliance, he reported having decided most cases, except for four inherited cases that remained unresolved due to incomplete transcripts of stenographic notes and the transfer of stenographers.
The Office of the Court Administrator (OCA) verified that of the cases enumerated, Judge Loja incurred no delay in seven, decided thirteen beyond the period, and left four undecided. One case from the list of unacted-upon cases also remained unresolved. The OCA noted that Judge Loja should be held responsible for thirteen cases with delays ranging from one day to over eight years, and for five total cases left unresolved upon retirement.
ISSUE
Whether Judge Guillermo L. Loja is administratively liable for failure to decide cases within the reglementary period.
RULING
Yes, Judge Loja is administratively liable for gross inefficiency. The Constitution and the Code of Judicial Conduct mandate that lower court cases must be decided within three months from submission. A judge’s failure to comply with this period constitutes gross inefficiency, warranting administrative sanction. The Court rejected Judge Loja’s explanation that incomplete transcripts and staff transfers caused the delays. Jurisprudence firmly establishes that judges must take notes and proceed with decision preparation even without complete transcripts, as the reglementary period continues to run regardless. Furthermore, judges are permitted to request extensions for justifiable reasons, which Judge Loja did not do.
While the Court found the delays inexcusable, it considered mitigating factors in determining the penalty. These included Judge Loja’s expeditious action in complying with the Court’s resolution to decide the pending cases, his demonstrated effort to fulfill his duties, and his excellent past performance record in case disposal. Consequently, the Court adopted the OCA’s recommendation for a nominal fine but reduced the amount. Judge Guillermo L. Loja was found guilty of gross inefficiency and fined Two Thousand Pesos (P2,000.00), to be deducted from his retirement benefits.