AM 97 1 08; (December, 1997) (Digest)
G.R. No. A.M. No. 97-1-08-MTC December 5, 1997
REPORT ON THE JUDICIAL AUDIT CONDUCTED IN MUNICIPAL TRIAL COURT, SIBULAN, NEGROS ORIENTAL
FACTS
A judicial audit was conducted in the Municipal Trial Court (MTC) of Sibulan, Negros Oriental, due to the impending compulsory retirement of its Presiding Judge, Antonio E. Arnaiz. The audit, as of December 10, 1996, revealed a total caseload of 83 cases (60 criminal, 23 civil). The Court, in a resolution dated January 28, 1997, gave due course to Judge Arnaiz’s retirement but withheld P6,000.00 from his benefits due to his failure to decide or resolve Criminal Case No. 2491 and Civil Cases Nos. 336 and 371 within the reglementary period. The Court also designated Judge Ananson E. Jayme as Acting Presiding Judge and directed the Clerk of Court, Elfrina T. Dipaling, to report on the status of specific cases. In her compliance, Clerk of Court Dipaling reported that Judge Arnaiz left three cases undecided or unresolved: Criminal Case No. 2276 (no decision rendered as defense counsel failed to submit a memorandum), Criminal Case No. 2491 (no resolution on a Motion for a Writ of Attachment), and Civil Case No. 336 (Motion to Dismiss unresolved). Judge Jayme subsequently sought reconsideration of his designation, noting that Judge Fe Lualhati D. Bustamante had already been designated as Acting Presiding Judge by the Executive Judge. The Office of the Court Administrator (OCA) evaluated the matter and recommended imposing a fine on Judge Arnaiz for the three undecided cases and designating Judge Bustamante as the Acting Presiding Judge instead of Judge Jayme.
ISSUE
Whether Judge Antonio E. Arnaiz should be held administratively liable for his failure to decide or resolve cases within the reglementary period, and who should properly be designated as the Acting Presiding Judge of the MTC of Sibulan, Negros Oriental.
RULING
The Court adopted the recommendations of the OCA. Judge Antonio E. Arnaiz was found administratively liable for gross inefficiency due to his failure to decide Criminal Case No. 2276 and Criminal Case No. 2491 and to resolve Civil Case No. 336 within the prescribed period. The Court emphasized that judges must decide cases promptly and that failure to do so without requesting an extension constitutes gross inefficiency. A fine of One Thousand Pesos (P1,000.00) was imposed on Judge Arnaiz, to be taken from the amount previously withheld from his retirement benefits. The balance of Five Thousand Pesos (P5,000.00) was ordered released. Furthermore, the Court set aside its prior resolution designating Judge Ananson E. Jayme as Acting Presiding Judge and instead designated Judge Fe D. Bustamante as the Acting Presiding Judge of the MTC of Sibulan, Negros Oriental.