AM 99 1 16 RTC; (June, 1999) (Digest)
A.M. No. 99-1-16-RTC June 21, 1999
REQUEST OF JUDGE IRMA ZITA V. MASAMAYOR, RTC-Br. 52, Talibon, Bohol for Extension of Time to Decide Crim. Case No. 96-185
FACTS
Judge Irma Zita V. Masamayor requested an extension of time to decide Criminal Case No. 96-185, but her request was filed on November 18, 1998, after the reglementary period had already expired on October 28, 1998. Her stated ground was the case’s complex legal questions and her court’s heavy caseload. The Court required her to explain the tardy request. Without waiting for a grant of her first extension, she presumed a 90-day extension and subsequently filed a second request for an additional 30 days on January 26, 1999. The Office of the Court Administrator noted this was not her first infraction, having a prior pending administrative case for similar delay, and recommended disciplinary action for gross inefficiency.
In her compliance, Judge Masamayor explained she had decided the case by February 24, 1999, and attributed the late filing of her extension request to “inadvertence.” She detailed her personal efforts to manage deadlines and her court’s heavy workload, also disclosing another instance where she filed a request for extension in a different criminal case after the deadline had lapsed.
ISSUE
Whether Judge Irma Zita V. Masamayor is administratively liable for her failure to decide a case within the reglementary period and to request an extension of time prior to the lapse of that period.
RULING
Yes, Judge Masamayor is administratively liable for gross inefficiency. The Court emphasized that while it is cognizant of heavy caseloads and may grant extensions, any request for such an extension must be made before the expiration of the reglementary period. Judge Masamayor’s failure to do so—not once but in multiple instances as admitted in her own report—demonstrates a lack of diligence in managing her court docket. Her explanation of “inadvertence” is insufficient, as a judge is duty-bound to be aware of submission dates to comply with the constitutional mandate for the speedy disposition of cases. This pattern of failing to seasonably request extensions constitutes gross inefficiency. Applying precedent, the Court found her guilty and imposed a fine of Five Thousand Pesos (P5,000.00) with a stern warning that a repetition would be dealt with more severely.