G.R. No. A.M. No. 18-07-142-RTC. February 15, 2022.
RE: REPORTS ON THE ERAFFLE PROCEDURE IN THE REGIONAL TRIAL COURT, MANILA.

FACTS

This administrative matter originated from reports of delays in the electronic raffle (eRaffle) and distribution of cases in the Regional Trial Court (RTC) of Manila following the implementation of the eCourt system. The eCourt system, launched in 2013 and piloted in high-volume courts, is designed for automated case management, including real-time docketing and raffling of cases. In 2016, 120 eCourts were set up in Manila, Pasig, and Mandaluyong. RTC Manila personnel underwent eCourt training from June to July 2017, and the Office of the Clerk of Court (OCC) began encoding cases on July 3, 2017. Subsequently, the Office of the Court Administrator (OCA) received reports of persistent delays. An OCA Audit Team investigation in January 2018 found that cases filed daily were raffled simultaneously in the afternoon, with delays of several days before transmittal to the assigned branches. The OCA directed then Executive Judge Reynaldo A. Alhambra to implement immediate encoding and eRaffle. A follow-up audit in May 2018 found a backlog of hundreds of cases pending raffle. It was also discovered that criminal cases with motions for consolidation were first referred to Judge Alhambra for evaluation before raffle. A dialogue with judges in July 2018 revealed complaints about delays in eRaffle, transmittal of records, issuance of commitment orders, and Judge Alhambra’s action on bail applications in cases already raffled to other branches. Acting on OCA recommendations, the Court En Banc issued Resolutions: on July 17, 2018, relieving Judge Alhambra as Executive Judge and designating new executive judges; and on July 24, 2018, preventively suspending Clerk of Court Atty. Jennifer H. Dela Cruz-Buendia and Assistant Clerk of Court Atty. Clemente M. Clemente for 90 days. A subsequent spot audit found that under the new leadership of Executive Judge Thelma B. Medina and OIC Atty. Marilou M. Anigan, real-time eRaffle was achieved within a month. The audit also confirmed Judge Alhambra approved bail applications in cases already raffled to other branches and found no uniform procedure for executing orders of forfeiture of bonds. The Court then directed Judge Alhambra, Atty. Dela Cruz-Buendia, and Judge Clemente (in his former capacity) to explain their failures.

ISSUE

Whether the respondents, former Executive Judge Reynaldo A. Alhambra, former Clerk of Court Atty. Jennifer H. Dela Cruz-Buendia, and former Assistant Clerk of Court (now Judge) Clemente M. Clemente, are administratively liable for the delays in the eRaffle procedure and related irregularities in the RTC Manila.

RULING

The Court found the respondents administratively liable.
1. Judge Reynaldo A. Alhambra was found guilty of Gross Ignorance of the Law and Procedure and Gross Misconduct. He violated the rule that once a case is raffled, jurisdiction is transferred to the assigned judge, by approving bail applications in 12 criminal cases already raffled to other branches. His claim of good faith was rejected. He also failed, as Executive Judge, to decisively address the eRaffle delays despite being aware of the problems, showing gross inefficiency. He was FINED Two Hundred Thousand Pesos (P200,000.00), deductible from his retirement benefits, with a STERN WARNING.
2. Atty. Jennifer H. Dela Cruz-Buendia, as Clerk of Court, was found guilty of Gross Neglect of Duty and Gross Inefficiency. She failed to ensure the efficient implementation of the eCourt system, leading to significant backlogs and delays in raffling and transmittal of cases. Her excuses (influx of drug cases, internet issues, lack of personnel) were deemed insufficient as she did not exhaust all measures to resolve them. She was FINED Forty Thousand Pesos (P40,000.00), deductible from her withheld benefits, with a STERN WARNING.
3. Judge Clemente M. Clemente, in his former capacity as Assistant Clerk of Court, was found guilty of Simple Neglect of Duty. While he shared responsibility for the delays, his subordinate role and the lack of evidence showing he willfully ignored directives mitigated his liability. He was FINED Five Thousand Pesos (P5,000.00), deductible from his withheld benefits, with a STERN WARNING.
The Court emphasized the imperative for court officials and personnel to uphold the prompt administration of justice, especially with the implementation of systems like eCourt designed to enhance efficiency.