A.M. No. 05-8-539-RTC. November 11, 2005.
RE: JUDICIAL AUDIT CONDUCTED IN THE REGIONAL TRIAL COURT, BRANCH 54, LAPU-LAPU CITY.

FACTS

A judicial audit was conducted in April 2005 at RTC, Branch 54, Lapu-Lapu City, in view of the compulsory retirement of Presiding Judge Rumoldo R. Fernandez. The audit revealed a total caseload of 962 cases. Among the deficiencies found were four cases submitted for decision already beyond the reglementary period, overdue resolutions of pending incidents in 15 cases, failure to act on 112 dormant cases, and delays in the cancellation of bail bonds. The audit also noted the late submission of the Semestral Docket Inventory and monthly reports. The Office of the Court Administrator (OCA) directed Judge Fernandez and Branch Clerk of Court Atty. Denis L. Pacas to explain and comply.
Judge Fernandez, in his compliance, reported having decided most of the criminal cases and working on the remaining civil cases and pending incidents, requesting an extension until June 15, 2005. He cited his heavy caseload and limited resources. Atty. Pacas attributed the reporting delays to his heavy workload and recent assumption to the position in March 2004. Judge Fernandez compulsorily retired on July 1, 2005.

ISSUE

Whether Judge Rumoldo R. Fernandez and Atty. Denis L. Pacas are administratively liable for the deficiencies uncovered by the judicial audit.

RULING

Yes. The Supreme Court found Judge Fernandez guilty of gross inefficiency. The constitutional mandate and the Code of Judicial Conduct require judges to dispose of the court’s business promptly and decide cases within the required periods. The Court emphasized that failure to decide cases and resolve incidents within the reglementary period constitutes gross inefficiency, warranting administrative sanction. While the Court acknowledged the heavy caseload, it ruled that this does not excuse a judge from complying with mandatory periods, as judges are presumed to manage their dockets to avoid delays. Judge Fernandez’s explanations were deemed unsatisfactory. However, considering his retirement and the OCA’s findings that he had substantially complied before retirement, the fine was reduced from the OCA’s recommended Twenty Thousand Pesos (P20,000.00) to Ten Thousand Pesos (P10,000.00), to be deducted from his retirement benefits.
As for Atty. Pacas, the Court found him administratively liable for failure to submit the required inventory and reports on time, in violation of pertinent administrative circulars. He was admonished and sternly warned that a repetition would be dealt with more severely. The Court stressed that court personnel must be circumspect in their duties to ensure the prompt administration of justice.