A.M. No. 02-8-188-MTCC; July 17, 2003
REPORT ON THE JUDICIAL AUDIT CONDUCTED IN THE MTCC-Brs. 1, 2 & 3, Mandaue City

FACTS

A judicial audit and physical inventory of cases were conducted in January 2002 in three branches of the Mandaue City MTCC, presided by Judges Rogelio S. Lucmayon (Branch 1), Carlos C. Fernando (Branch 2), and Wilfredo A. Dagatan (Branch 3). The audit revealed significant delays and inaction across all branches. Numerous cases were undecided beyond the mandatory period, while others remained unacted upon for a considerable length of time. Specific directives were issued by the Court requiring the judges to explain the delays, decide/resolve the pending cases, and submit compliance reports. Clerks of Court Paulita M. Soon and Rudy R. Magale were also directed to explain their inaction on specific cases and failure to transmit records.

ISSUE

Whether the respondent judges and court personnel should be held administratively liable for their failure to decide cases within the reglementary period and to act on cases with dispatch, thereby violating the constitutional mandate for a speedy disposition of cases.

RULING

Yes. The Court found the respondents administratively liable. The constitutional right to a speedy disposition of cases is paramount. Judges are mandated to decide cases within 90 days from submission, and failure to do so constitutes gross inefficiency warranting administrative sanction. The reasons offered by the respondents—such as heavy caseload, health problems, and incomplete transcripts—were deemed insufficient. Heavy caseload is an inherent part of judicial duty and does not excuse delay. Health issues, while considered in mitigation, do not absolve a judge from liability, especially when no formal leave or request for extension was made. The Court emphasized that judges must request extensions from the Court before the expiration of the period. For the clerks of court, their failure to perform ministerial duties contributing to the delay also constituted neglect of duty. Accordingly, Judge Fernando was fined P20,000; Judge Dagatan was fined P10,000; and Judge Lucmayon was sternly warned. Clerks of Court Soon and Magale were also fined P2,000 each. All were directed to decide or resolve the remaining cases immediately.