A.M. OCA IPI No. 04-1606-MTJ; September 19, 2012
Atty. Arturo Juanito T. Maturan, Complainant, vs. Judge Lizabeth Gutierrez-Torres, Respondent.

FACTS

Complainant Atty. Arturo Juanito T. Maturan, counsel for the private complainant in People v. Anicia C. Ventanilla (Criminal Case No. 67659), filed an administrative complaint against respondent Judge Lizabeth Gutierrez-Torres, former Presiding Judge of the Metropolitan Trial Court, Branch 60, Mandaluyong City, for undue delay in rendering a decision. The criminal case was submitted for decision on June 3, 2002, following the filing of the prosecution’s memorandum. Despite three successive motions to decide filed by the prosecution in December 2002, July 2003, and February 2004, the respondent judge failed to render judgment. By the time the complaint was filed in August 2004, more than two years had lapsed from the submission of the case, well beyond the constitutional 90-day period.
The Office of the Court Administrator (OCA) directed the respondent to comment on the complaint. Although the Court granted her multiple requests for extension, she consistently failed to submit the required comment despite repeated directives and a show-cause order. This prompted the OCA to note her indifference and blatant insubordination towards the Court’s lawful orders.

ISSUE

Whether respondent Judge Lizabeth Gutierrez-Torres is administratively liable for gross inefficiency due to undue delay in rendering a decision and for insubordination for failing to comply with the Court’s directives to file her comment.

RULING

Yes, the respondent is administratively liable. The Court found her guilty of gross inefficiency for unjustifiably delaying the disposition of Criminal Case No. 67659 for over two years, a clear violation of Section 15, Article VIII of the 1987 Constitution and Canon 3, Rule 3.05 of the Code of Judicial Conduct, which mandates judges to dispose of court business promptly. The legal logic is straightforward: the constitutional and ethical duty to decide cases within the prescribed period is mandatory to ensure the speedy administration of justice. Failure to do so, without a granted extension, constitutes inefficiency warranting administrative sanction.
Furthermore, her repeated failure to comply with the Court’s directives to file a comment, despite several indulgences, constituted gross misconduct and insubordination. The Court emphasized that its resolutions are not mere requests but lawful orders demanding strict compliance. Her indifference demonstrated disrespect for judicial authority and an absence of credible defense. Considering she had already been dismissed from service in a separate case for similar delay, the Court, applying Rule 140 of the Rules of Court as amended, imposed a fine of Twenty Thousand Pesos (₱20,000.00) for the less serious charge of undue delay. She was also ordered to show cause why she should not be suspended from the Integrated Bar of the Philippines for her insubordination.