G.R. No. A.M. No. 95-4-41-MeTC December 10, 1996
Quarterly Report of [Inherited] Cases of Judge Evelyn Corpuz-Cabochan, MeTC, Br. 82, Valenzuela, Metro Manila; and Related Matter of Undecided Cases of Judge Floro P. Alejo, Regional Trial Court at Valenzuela, Metro Manila [Branch 172] [Formerly, Presiding Judge of the MeTC at Malabon, Metro Manila].

FACTS

This administrative matter originated from a backlog of cases at the Metropolitan Trial Court (MeTC) Branch 82 in Valenzuela. Judge Floro P. Alejo was detailed as its presiding judge from June 1987 to January 1990, following the resignation of Judge Antonio Serapio. Upon Judge Evelyn Corpuz-Cabochan’s appointment to Branch 82 in 1990, she inherited 179 cases submitted for decision, 89 of which were from Judge Alejo’s detail. In an April 1995 letter to the Court Administrator, Judge Cabochan formally reported the pending 23 civil and 66 criminal cases left undecided by Judge Alejo, prompting an investigation.
Judge Alejo, in his comment, admitted failing to decide 50 criminal and 23 civil cases within the reglementary period. He explained that 24 criminal cases were inherited from his predecessor, and for the remaining 26, he misplaced his notes and encountered difficulty in having the transcripts of stenographic notes transcribed. He acknowledged this was not a valid excuse. He also cited his heavy workload, including assignments to other courts to help reduce their dockets, and noted a nomination for a judicial excellence award by the IBP.

ISSUE

Whether Judge Floro P. Alejo should be held administratively liable for his failure to decide cases within the reglementary period during his detail at MeTC Branch 82.

RULING

Yes, Judge Alejo is administratively liable. The Supreme Court emphasized that judges have a mandatory duty to decide cases promptly and within the periods fixed by law and the Constitution. Failure to do so constitutes gross inefficiency and warrants administrative sanction. Judge Alejo’s admissions—misplacing trial notes and encountering transcription difficulties—are not justifiable excuses for the delay. The Court firmly stated that such negligence cannot be tolerated, as it undermines the efficient administration of justice and public confidence in the judiciary.
However, in determining the penalty, the Court considered mitigating circumstances. It noted Judge Alejo’s candor in admitting his fault, his demonstrated willingness to undertake extra judicial work in other courts to alleviate case backlogs, and his previously unblemished record as evidenced by his nomination for a judicial award. While these factors do not exonerate him, they persuaded the Court to exercise judicial clemency. Consequently, instead of imposing a heavier penalty like suspension or fine, the Court deemed a severe reprimand to be sufficient under the specific circumstances of this case. Judge Alejo was sternly admonished to be more diligent and scrupulous in observing mandatory decision periods in the future.