AM 2668 Mj; (May, 1982) (Digest)
G.R. No. 2668 -MJ. May 22, 1982
Mariano B. Laurel, petitioner, vs. Judge Hermenegildo C. Cruz, Municipal Court of Mandaluyong, Metro Manila, respondent.
FACTS
The petitioner, Mariano B. Laurel, filed an administrative complaint against respondent Judge Hermenegildo C. Cruz for failing to decide Civil Case No. 7772 within the 90-day period mandated by law. The case was submitted for decision on December 28, 1979, making the deadline for rendition of judgment March 28, 1980. The judge failed to meet this deadline.
In his comment, Judge Cruz admitted the delay. He explained that the delay was caused by the inability to locate the original transcript of stenographic notes, as the stenographer, V.V. Bustamante, had left for abroad without proper clearance. The transcript was only found during the court’s annual inventory in December 1981, after which a decision was promptly rendered on December 28, 1981.
ISSUE
Whether respondent Judge Hermenegildo C. Cruz is administratively liable for his failure to decide a case within the 90-day reglementary period.
RULING
Yes, the respondent judge is administratively liable. The Supreme Court found his explanation for the delay unsatisfactory. The legal logic is clear and strict: once a case is submitted for decision, the duty to collate all records, transcripts, and exhibits and to prepare the decision within 90 days rests solely upon the judge. This is a non-negotiable constitutional and statutory mandate designed to ensure the speedy disposition of cases. The judge’s responsibility for court records and personnel is managerial and cannot be delegated or excused by the alleged negligence or absence of a stenographer. The loss or misplacement of a transcript is a failure of the judge’s supervisory duty over court records and does not justify a delay exceeding two years.
However, in determining the appropriate penalty, the Court considered mitigating factors. These included the respondent judge’s heavy caseload, his overall record of disposing of numerous cases in 1980 and 1981, and the fact that this was his first such infraction. In light of these circumstances, the Court exercised leniency. Accordingly, Judge Hermenegildo C. Cruz was ADMONISHED to be more assiduous in his duties and WARNED that a repetition of the same offense would be dealt with more severely. The resolution serves to emphasize the imperative of timely decision-making while recognizing equitable considerations in administrative discipline.