AM 02 8 441 RTC; (March, 2004) (Digest)
A.M. No. 02-8-441-RTC ; March 3, 2004
RE: REPORT ON THE JUDICIAL AUDIT CONDUCTED IN THE RTC, BRANCH 22, KABACAN, NORTH COTABATO
FACTS
A judicial audit was conducted on July 9, 2002, at the Regional Trial Court, Branch 22, Kabacan, North Cotabato, in view of the compulsory retirement of Presiding Judge Braulio L. Hurtado. The audit revealed a caseload of 274 cases, with 70 criminal cases and 4 civil cases submitted for decision, and several other cases with pending incidents for resolution. The Court, via a Resolution dated September 2, 2002, directed Judge Hurtado to explain his failure to decide or resolve numerous cases within the reglementary period.
In his compliance, Judge Hurtado explained that his failure to decide 40 cases was due to his previous six-month designation as Acting Presiding Judge in Surallah. He also reported that some pending incidents had been resolved and one case was promulgated as scheduled. The Office of the Court Administrator (OCA), in its evaluation, found this explanation unsatisfactory, noting that the Surallah designation occurred from 1997 to 1999, while most of the undecided cases became due in 2000. The OCA recommended that Judge Hurtado be fined Fifty Thousand Pesos (P50,000.00).
ISSUE
Whether Judge Braulio L. Hurtado should be held administratively liable for his failure to decide cases within the reglementary period.
RULING
Yes, Judge Hurtado is administratively liable. The Constitution and the Code of Judicial Conduct mandate judges to decide cases and resolve matters within specified periods. Failure to do so constitutes gross inefficiency and warrants administrative sanction. The Court found Judge Hurtado’s proffered excuse of a previous designation unpersuasive, as the temporal gap between that assignment and the due dates of the undecided cases negated a causal link. His failure constituted undue delay in the administration of justice.
However, the Court considered the mitigating circumstance that this was his first offense in a long tenure on the bench. Balancing the gravity of the infraction—the failure to decide a significant number of cases—with this mitigating factor, the Court found the OCA’s recommended penalty appropriate. Accordingly, Judge Braulio L. Hurtado was FINED the amount of Fifty Thousand Pesos (P50,000.00), to be deducted from his retirement benefits. The compliance submitted by the court personnel and the acting judge were noted, with directives to address the remaining case matters.
