GR L 27657; (August, 1982) (Digest)
March 15, 2026GR 88724; (April, 1990) (Digest)
March 15, 2026G.R. No. RTJ-94-4-156. March 13, 1996. REPORT ON THE JUDICIAL AUDIT AND PHYSICAL INVENTORY OF THE CASES IN RTC-BR. 138, MAKATI CITY, JUDGE FERNANDO P. AGDAMAG, respondent.
FACTS
A judicial audit of RTC-Br. 138, Makati City, then presided by Judge Fernando P. Agdamag, revealed that as of February 1994, the court had 860 total cases. Among these, 278 cases were submitted for decision but remained undecided, with 250 of them already beyond the 90-day reglementary period. Some cases had been pending since 1985. This massive backlog starkly contradicted Judge Agdamag’s Monthly Report of Cases for December 1993, which falsely indicated only one case was submitted for decision. The audit also noted his frequent leaves of absence throughout 1993 and 1994. Required to explain, Judge Agdamag attributed the backlog to prolonged absences of a clerk of court and later claimed the erroneous report was prepared by a staff member following a local practice. He also cited his efforts to process retirement, resolved 100 cases post-audit, his health issues, and his long, previously unblemished government service. He had compulsorily retired on May 30, 1994.
ISSUE
Whether Judge Agdamag is administratively liable for gross inefficiency and misconduct due to his failure to decide cases within the reglementary period and for submitting a fraudulent monthly report.
RULING
Yes, Judge Agdamag is administratively liable. The Court found his explanations utterly unsatisfactory and aggravating. His failure to decide 250 cases within the mandatory 90-day period constitutes gross inefficiency and a blatant violation of Rule 3.05, Canon 3, of the Code of Judicial Conduct, which mandates prompt disposition of court business. The Court emphasized that judges have a sworn duty to administer justice without undue delay, as justice delayed is justice denied. His claim that a staff member prepared the misleading monthly report does not exculpate him; as the presiding judge, he bears the primary responsibility for proper court management and the accuracy of reports under his signature pursuant to Rule 3.09. By signing the false certification, he committed gross misconduct, as it constituted a fraudulent abdication of his duty to safeguard the constitutional right to a speedy disposition of cases. His actions hindered judicial efforts to decongest court dockets. Considering his compulsory retirement, age, and health, the Court imposed a fine of P40,000.00, to be deducted from the amount previously withheld from his retirement benefits.
