A.M. No. 19-12-293-RTC, June 30, 2020
RE: RESULT OF THE JUDICIAL AUDIT CONDUCTED IN BRANCH 49, REGIONAL TRIAL COURT, PUERTO PRINCESA CITY, PALAWAN

FACTS

A judicial audit conducted in March 2014 at the Regional Trial Court (RTC), Branch 49, Puerto Princesa City, Palawan, then presided by Judge Leopoldo Mario P. Legazpi, revealed numerous deficiencies. The audit found: (1) 88 cases submitted for decision, 79 of which were beyond the reglementary period; (2) 51 cases with pending incidents submitted for resolution, 40 beyond the period; (3) 49 cases with no action or setting for a considerable time; (4) 3 cases with no initial action; and (5) 24 cases due for archiving. The cases were not properly reflected in monthly reports, and there was no record of Judge Legazpi requesting extensions to decide them. A delay in deciding appealed cases, violating court rules, was also noted. Judge Legazpi, in his explanation, cited factors such as inheriting a heavy docket, implementing a strict trial calendar that expedited case submissions, chronic vacancies in other branches and in his own court personnel (including Branch Clerk of Court, legal researcher, and stenographers), and his serious health conditions (diabetes and a neck tumor). He stated he concentrated on judicial work and delegated administrative tasks. He filed a resignation effective March 15, 2015, due to health reasons. The Office of the Court Administrator (OCA) recommended the case be re-docketed as a regular administrative matter and that Judge Legazpi be found guilty of gross inefficiency and fined Fifty Thousand Pesos (P50,000.00).

ISSUE

Whether or not Judge Leopoldo Mario P. Legazpi should be held administratively liable.

RULING

Yes, Judge Legazpi is administratively liable. The Court found him GUILTY of gross inefficiency and imposed a FINE of P50,000.00, to be deducted from his accrued leave credits. The Constitution and the Code of Judicial Conduct mandate judges to decide cases within the reglementary period (90 days). Failure to do so without strong justification constitutes a serious violation of the parties’ right to a speedy disposition and amounts to gross inefficiency. The Court held that Judge Legazpi’s reasons—heavy workload, lack of personnel, and health problems—did not excuse the delay. These circumstances did not prevent him from requesting extensions of time from the Court, which he failed to do. The audit noted that transcripts were complete and draft decisions were prepared by staff, yet he did not finalize them. His resignation did not preclude the finding of administrative liability. The OCA’s recommendations were adopted.