A.M. No. 97-8-262-RTC November 27, 1998
RE: REPORT ON THE JUDICIAL AUDIT OF CASES IN THE REGIONAL TRIAL COURT, BRANCH 35, IRIGA CITY

FACTS

A judicial audit of Branch 35, RTC, Iriga City, revealed several administrative lapses by then Presiding Judge Reno R. Gonzales. The audit found that Judge Gonzales failed to decide three civil cases within the constitutionally mandated 90-day period. He also failed to act for an unreasonable length of time on eight other cases, including civil, land registration, and special proceedings cases. Furthermore, he failed to archive ten criminal cases where the accused had remained at large, as required by administrative circulars. Judge Gonzales retired on the very day the audit report was submitted. In his required comment, he offered various explanations, attributing delays to his designation to other courts, the loss of interest by parties, the failure of government agencies to submit reports, and the medical absence of his clerk of court.

ISSUE

Whether Judge Reno R. Gonzales is administratively liable for gross inefficiency due to his failure to decide cases promptly, act on cases with dispatch, and archive dormant criminal cases in accordance with the rules.

RULING

Yes, Judge Gonzales is administratively liable. The Court emphasized that the constitutional mandate for lower courts to decide cases within three months from submission is fundamental, as justice delayed is justice denied. Canon 3, Rules 3.05 and 3.09 of the Code of Judicial Conduct impose upon judges the duty to dispose of court business promptly and to supervise court personnel to ensure efficient dispatch of business. The Court found Judge Gonzales’s explanations unsatisfactory. His failure to even mention one overdue case, his claim of being an acting judge in other salas (which did not excuse him from seeking an extension), and his unverified claim about an uncertain submission date for another case constituted gross inefficiency. While some explanations for the inaction on other cases were accepted, his failure to manage his docket to prevent a case from being “inadvertently omitted” from the calendar for over seven months was a breach of duty. His excuse for not archiving cases—his clerk of court’s surgery—was unacceptable, as he could have delegated the task. Considering the number and nature of infractions, and following precedents, the Court imposed a fine of Twenty Thousand Pesos (P20,000.00) to be deducted from his retirement benefits. The Court also granted the request of his temporary replacement, Judge Martin P. Badong, Jr., to be relieved.