AM 99 7 250 RTC; (April, 2000) (Digest)
A.M. No. 99-7-250-RTC; April 5, 2000
RE: CASES SUBMITTED FOR DECISION BEFORE RETIRED JUDGE MAXIMO A. SAVELLANO, JR., RTC-BRANCH 53, MANILA
FACTS
This administrative case concerns the non-resolution within the reglementary period of multiple criminal and civil cases before the Regional Trial Court of Manila, Branch 53, then presided by Executive Judge Maximo A. Savellano, Jr., who compulsorily retired in March 1999. An audit revealed that Judge Savellano left several cases unresolved for an unreasonable length of time and decided at least ten cases beyond the 90-day constitutional period. Furthermore, his monthly reports of cases failed to accurately list these pending matters. In his defense, Judge Savellano argued that these cases were not yet submitted for decision because the parties had failed to file their required memoranda, despite his subsequent orders granting them extensions. He also cited his heavy workload as an Executive Judge concurrently handling a special criminal court.
ISSUE
Whether Judge Maximo A. Savellano, Jr. is administratively liable for undue delay in rendering decisions and for violating Supreme Court rules and circulars.
RULING
Yes, Judge Savellano is administratively liable. The Supreme Court rejected his explanations, applying the clear provisions of Administrative Circular No. 28 dated 03 July 1989. The Circular states that a case is deemed submitted for decision upon the termination of trial and the admission of evidence. The filing of memoranda is discretionary for the court and is not a mandatory part of the proceedings. Crucially, the 90-day period for deciding a case commences from the submission of the case for decision without memoranda; if memoranda are allowed, the period runs from the filing of the last memorandum or the expiration of the period to file it. Granting extensions for filing memoranda does not interrupt this 90-day period.
The legal logic is that judges must decide cases based on the evidence already presented and their personal notes from the trial. The non-submission of a memorandum constitutes a waiver of that privilege and does not justify delay. The Court emphasized that Rule 3.05 of the Code of Judicial Conduct mandates judges to dispose of court business promptly and within legal periods. While heavy caseloads or complex issues may warrant an extension, Judge Savellano did not seek such leave from the Court. His failure to decide cases within the reglementary period and his inaccurate reporting constitute violations that undermine public confidence in the judiciary. Accordingly, the Court found him liable for undue delay and imposed a fine of Five Thousand Pesos (P5,000.00).