AM 04 9 512 RTC; (December, 2005) (Digest)
A.M. No. 04-9-512-RTC. December 13, 2005. REPORT ON THE JUDICIAL AUDIT CONDUCTED IN THE RTC, BRANCH 18, TAGAYTAY CITY.
FACTS:
Prior to his compulsory retirement, Judge Alfonso S. Garcia of the RTC, Branch 18, Tagaytay City, was directed by the Supreme Court to decide all pending cases and resolve motions. A subsequent judicial audit revealed that despite a prior directive, Judge Garcia left unresolved a number of cases upon his retirement. The Office of the Court Administrator (OCA) reported that he failed to decide ten (10) cases submitted directly to him for decision and fourteen (14) cases inherited from his predecessors, which were already beyond the reglementary period for decision.
Judge Garcia submitted a compliance, arguing that some cases were listed twice and that he had decided many others. The OCA acknowledged the duplicate listings, which adjusted the total number of unresolved cases, but confirmed that a significant number remained undecided. The audit further established that Judge Garcia had been specifically ordered to cease trying new cases and focus solely on deciding the backlog, yet he still retired leaving cases unresolved.
ISSUE
Whether Judge Alfonso S. Garcia is administratively liable for undue delay in rendering decisions.
RULING
Yes, Judge Garcia is administratively liable. The Supreme Court emphasized that judges have a constitutional and ethical duty to decide cases promptly within three months from the filing of the last pleading, as mandated by Section 15, Article VIII of the Constitution and Canon 3, Rule 3.05 of the Code of Judicial Conduct. Failure to comply constitutes gross inefficiency and undermines public confidence in the judiciary.
The Court found that Judge Garcia failed to decide a total of twenty-four (24) cases—ten submitted to him and fourteen inherited—despite explicit directives from the Court to resolve them before his retirement. This undue delay is classified as a less serious charge under Section 9, Rule 140 of the Revised Rules of Court. Applying the sanctions under Section 11(B) for less serious offenses, and considering precedent where a fine of ₱11,000 was imposed for similar infractions, the Court deemed a fine appropriate. Since Judge Garcia had already retired, the fine was ordered to be deducted from his retirement benefits. The penalty serves to uphold the judiciary’s standards and deter similar delays.