A.M. No. 06-4-219-RTC; November 2, 2006
RE: REPORT ON THE JUDICIAL AUDIT AND PHYSICAL INVENTORY OF CASES IN THE REGIONAL TRIAL COURT, BRANCH 54, BACOLOD CITY.

FACTS

A judicial audit of the Regional Trial Court, Branch 54, Bacolod City, presided by Judge Demosthenes L. Magallanes, revealed a severe backlog. Of 450 pending cases, 116 were submitted for decision, with only 4 still within the 90-day reglementary period. Sixty cases had pending motions or incidents for resolution, mostly beyond the mandatory period. Seventy-four cases had no action taken for a considerable time. Notably, some criminal cases submitted for decision as early as 1995 and 1996 remained undecided. Judge Magallanes cited health problems as a cause for the delay but admitted he never requested extensions of time to decide. The audit team recommended designating an assisting judge and giving Judge Magallanes six months to decide the 116 cases and two months to resolve the pending motions.
The Office of the Court Administrator (OCA) directed Judge Magallanes to explain the delays and to decide/resolve the specified cases within set periods. In his compliance, Judge Magallanes claimed he had decided or resolved many cases, but verification showed his submissions were incomplete and, critically, he had been certifying in his monthly Certificates of Service that all cases had been decided within the period, which was false. Branch Clerk of Court Atty. Gia L. Arinday was also directed to explain inaction in several cases where she was authorized to receive evidence ex-parte.

ISSUE

Whether Judge Magallanes and Branch Clerk of Court Arinday are administratively liable for the findings of the judicial audit.

RULING

Yes. Judge Magallanes is guilty of undue delay in rendering decisions and making untruthful statements in his Certificates of Service. The constitutional right to a speedy disposition of cases is paramount. A judge’s failure to decide cases within the reglementary period constitutes gross inefficiency, and health problems do not absolve liability unless a formal request for extension is granted by the Supreme Court. Judge Magallanes’s inaction for years, especially on cases submitted in the mid-1990s, and his false certifications in his Certificates of Service, which undermined judicial integrity, are serious offenses warranting suspension.
Atty. Arinday is guilty of simple negligence. As branch clerk of court, she is tasked with assisting in the speedy administration of justice and ensuring the court’s efficient management. Her failure to act on cases assigned to her for ex-parte reception of evidence contributed to the court’s docket congestion. While her role is subordinate, she shares a corollary duty to help expedite cases.
Judge Magallanes is SUSPENDED for three months without salary and benefits. Atty. Arinday is FINED Five Thousand Pesos (₱5,000.00). Both are sternly warned that repetition will be dealt with more severely. Judge Magallanes is granted a six-month extension to clear the backlog, with a requirement to submit monthly reports to the OCA.