AM 2351; (April, 1981) (Digest)
G.R. No. 2351 -CFI April 27, 1981
IN RE JUDGE JOSE F. MADARA, Court of First Instance of Albay, Ligao Branch V.
FACTS
This administrative case concerns Judge Jose F. Madara’s handling of Civil Case No. 194. The case was submitted for decision on October 18, 1976. Judge Madara rendered a decision dated January 19, 1977, three days after the 90-day reglementary period expired. This decision, however, was not served on the parties until September 15-17, 1977, a delay of nearly eight months. The defendants filed a motion for reconsideration, submitted for resolution on November 11, 1977. Judge Madara issued an order granting the motion and reversing his own decision, dated February 8, 1978, on the 89th day of the 90-day period. This reversal order was not served on the parties until mid-July 1978, a delay exceeding five months. Further delays plagued the appeal process, including a more than one-year delay in acting on the record on appeal and a 54-day delay in transmitting it after approval, violating the 10-day rule.
ISSUE
Whether Judge Jose F. Madara should be held administratively liable for the delays and irregularities in the disposition of Civil Case No. 194.
RULING
Yes, Judge Madara is administratively liable. The Court found his explanations for the delays unsatisfactory. He attributed the delays in serving the decision and reversal order to his clerk’s health, “laches,” and the postal system. However, the prompt receipt of the mailed copies (within 2-4 days) once they were finally dispatched refuted claims of postal delay. The Court found that delays of seven and five months, respectively, could not be justified by a clerk’s alleged condition, for which the judge bore supervisory responsibility. The pattern of delay, coupled with the issuance of decisions and orders dated just within or after the reglementary period but served months later, created a strong impression of antedating to conceal non-compliance with the 90-day rule. This constituted gross inefficiency, negligence, and incompetence in case management. The expediente itself served as irrefutable evidence, making a formal investigation unnecessary. Judge Madara was found guilty of gross inefficiency, severely censured and reprimanded, and fined an amount equivalent to one month’s salary, with a warning for future infractions.