A.M. No. 02-8-471-RTC; March 14, 2003
RE: JUDICIAL AUDIT REPORT CONDUCTED IN THE REGIONAL TRIAL COURT, BRANCH 17, KIDAPAWAN CITY, JUDGE RODOLFO M. SERRANO, respondent.

FACTS

A judicial audit was conducted near the retirement of Judge Rodolfo M. Serrano of the RTC, Branch 17, Kidapawan City. The audit initially found he had failed to decide 150 cases and resolve pending incidents in 25 cases. A follow-up audit after his retirement on August 20, 2002, reduced the number to 82 undecided cases and 21 unresolved motions. The Court had earlier directed Judge Serrano to stop trying new cases and concentrate on deciding submitted cases, and it withheld P100,000 from his retirement benefits pending the administrative matter.
In his explanation, Judge Serrano cited his failing health, specifically cirrhosis of the liver diagnosed in May 2001, as the primary reason for the backlog. He also claimed that his request for relief from new case assignments to focus on backlog was granted only in June 2002, less than three months before his retirement. The Office of the Court Administrator (OCA) found his explanation insufficient, noting he did not request extensions for the delayed decisions.

ISSUE

Whether Judge Rodolfo M. Serrano is administratively liable for his failure to decide cases and resolve motions within the reglementary period prior to his retirement.

RULING

Yes, Judge Serrano is administratively liable. The Court emphasized that judges have a mandatory duty to decide cases and resolve motions within the periods fixed by law and the Constitution. Failure to do so constitutes gross inefficiency and is not excusable. While the Court acknowledged Judge Serrano’s illness as a mitigating circumstance, it ruled that this did not absolve him of liability. Serious health problems do not automatically excuse a judge from administrative sanction but may be considered in mitigation of the penalty. The Court cited precedents where fines were reduced due to judges’ serious illnesses.
The legal logic is clear: the duty to dispose of the court’s business promptly is paramount. A judge who is unable to perform this duty due to health reasons has the obligation to inform the Court and seek timely extensions or other appropriate relief, which Judge Serrano failed to do adequately. Consequently, the Court found him liable for gross inefficiency. Applying the mitigating circumstance of his illness, the Court imposed a fine of Five Thousand Pesos (P5,000.00), to be deducted from his withheld retirement benefits, aligning with jurisprudence for similar infractions under comparable mitigating conditions.