AM 94 6 189 RTC; (March, 1995) (Digest)
G.R. No. A.M. No. 94-6-189-RTC. March 7, 1995. RE: PARTIAL REPORT ON THE AUDIT AND INVENTORY OF CASES IN THE REGIONAL TRIAL COURT, BRANCHES 7 AND 8, TANAUAN, BATANGAS. JUDGE LIBERATO C. CORTES, PRESIDING OF BRANCH 8.
FACTS
An audit of the Regional Trial Court, Branch 8, Tanauan, Batangas, presided by Judge Liberato C. Cortes, revealed significant delays in case disposition. The audit uncovered that, as of March 31, 1994, Branch 8 had a total caseload of 386 cases. In 47 of these cases (15 criminal and 32 civil), no action had been taken for a considerable period. Furthermore, two criminal cases submitted for decision in August and October 1993 remained undecided by the audit date in May 1994. The Court required Judge Cortes to explain these delays.
In his explanation, Judge Cortes accepted a degree of responsibility, attributing the delays to inadequate management of time and resources. He cited mitigating circumstances, including poor court facilities, a lack of adequate legal research materials, and a stenographer problem, which he claimed hampered his efforts to resolve cases promptly.
ISSUE
Whether Judge Liberato C. Cortes is administratively liable for the inordinate delay in acting upon pending cases and in deciding cases submitted for resolution.
RULING
Yes, Judge Cortes is administratively liable. The Supreme Court found him guilty of gross neglect of duty. The legal logic is anchored on the non-delegable responsibility of a judge to ensure the prompt disposition of court business. While the Court acknowledged that the cited logistical problems (e.g., lack of stenographer, inadequate facilities) could serve as mitigating factors, they do not absolve a judge from liability. The Court emphasized that a judge is presumed to know the cases submitted for decision, especially those pending beyond the 90-day reglementary period, as reflected in the monthly Certificate of Service they are mandated to file.
Citing precedents like Nidua v. Lazaro, the Court ruled that proper and efficient court management is the judge’s personal responsibility. Judges cannot take refuge behind the inefficiency of court personnel. They are bound by the Code of Judicial Conduct, specifically Rule 3.01 (maintaining professional competence) and Rule 3.05 (disposing of court business promptly). The failure to decide cases within the required period constitutes gross inefficiency. Considering the gravity of the inaction, which impeded the administration of justice, and that this was not Judge Cortes’s first administrative sanction for neglect, the Court imposed a fine of Fifteen Thousand Pesos (P15,000.00) and issued a stern warning against future dilatoriness.