A.M. No. 144-CFI July 18, 1974
RUFINA BENDESULA, complainant, vs. JUDGE ALFREDO C. LAYA, CFI, CEBU, BRANCH XII, ARGAO, respondent.

FACTS

Complainant Rufina Bendesula wrote a letter to the President, later referred to the Supreme Court, charging Judge Alfredo C. Laya with undue delay in deciding Civil Case No. AV-177. The case, involving her son, had its trial terminated on March 17, 1972, but remained undecided for nearly a year. Respondent Judge, in his comment, attributed the delay to the parties’ failure to submit required memoranda and to an administrative lapse by his court’s docket clerk, who failed to bring an ex-parte motion for extension to the clerk of court’s attention, thus preventing the Judge from being alerted to the pending matter.
During the investigation, complainant, through counsel, submitted an affidavit of desistance, clarifying she never intended to file an administrative case but merely sought expedition of the civil suit. Respondent testified extensively on mitigating circumstances: his court in Argao was newly established, undermanned, and lacked adequate law books and facilities; he had to supervise inexperienced personnel personally; and he was burdened by having to continue hearing cases from previous temporary assignments. He decided the subject case on March 5, 1973, after being required to comment on the complaint.

ISSUE

Whether respondent Judge Alfredo C. Laya is administratively liable for the delay in deciding Civil Case No. AV-177.

RULING

Yes, respondent Judge is administratively liable, though mitigating circumstances warrant only an admonition. The legal logic is anchored on the mandatory duty of judges to decide cases within the reglementary period, irrespective of the submission of memoranda by the parties. Department of Justice Circular No. 64 explicitly states that non-submission of memoranda does not justify failure to decide. The 90-day period for decision, per Circular No. 17, begins from the expiry of the period fixed for memoranda. Therefore, respondent’s primary justification—that delay was caused by the parties’ inaction—is legally untenable.
The Court found that the delay of approximately ten months from the expiration of the extended period for memoranda until the decision was rendered constituted a clear violation. While the negligence of his inexperienced court staff in failing to call his attention to the pending case is a mitigating factor, it does not absolve the Judge of his ultimate responsibility. A judge, especially one aware of his personnel’s inexperience, must exercise extraordinary diligence and close supervision to ensure compliance with mandatory rules and prevent delays. The Court emphasized that delay erodes public confidence in the judiciary, making adherence to deadlines imperative.
However, the Court considered significant extenuating circumstances in respondent’s favor: his good faith, his immediate action to decide the case upon being apprised of the delay, his 23-year unblemished public service record, the genuine lack of facilities and trained personnel at his station, and the additional burden of handling cases from multiple branches. Consequently, instead of a severe penalty, the Court deemed an admonition sufficient, directing Judge Laya to be more careful, attentive, and vigilant in supervising his subordinates to prevent future infractions.