A.M. No. MTJ-10-1760. November 16, 2015.
Office of the Court Administrator, Petitioner, vs. Retired Judge Filemon A. Tandinco, Municipal Trial Court in Cities (MTCC), Calbayog City, Samar and Ronaldo C. Dioneda, Clerk of Court of the MTCC, Calbayog City, Samar, Respondents.

FACTS

This administrative matter arose from a judicial audit conducted at the MTCC of Calbayog City, Samar, then presided by Judge Filemon A. Tandinco, prior to his retirement. The audit revealed a total caseload of 940 cases. The audit team found that: (1) Judge Tandinco failed to resolve motions/incidents in 30 criminal and 67 civil cases; (2) Judge Tandinco failed to decide 46 criminal and 20 civil cases submitted for decision; (3) Assisting Judge Alma Uy-Lampasa (whose designation was later revoked) failed to resolve motions/incidents in 96 criminal and 32 civil cases; and (4) Judge Lampasa failed to decide 10 criminal and 8 civil cases. Furthermore, based on monthly reports, Judge Tandinco failed to decide an additional 24 criminal and 12 civil cases. Many case folders were not presented during the audit, records were inaccurate or incomplete, and no extensions of time to decide were requested. The audit also noted various administrative deficiencies in case management. The Office of the Court Administrator (OCA) recommended docketing the audit as an administrative case. Judge Tandinco, Judge Lampasa, and Clerk of Court Ronaldo C. Dioneda were directed to explain. Judge Lampasa cited her heavy workload across multiple courts and claimed the Clerk of Court did not bring pending motions to her attention. Dioneda submitted a chart but failed to sufficiently explain the non-presentation of specific case records. Judge Tandinco did not submit an explanation.

ISSUE

Whether respondents Judge Filemon A. Tandinco, Judge Alma Uy-Lampasa, and Clerk of Court Ronaldo C. Dioneda are administratively liable for the failures and deficiencies uncovered by the judicial audit.

RULING

The Supreme Court found the respondents administratively liable.
1. Retired Judge Filemon A. Tandinco is GUILTY of GROSS INCOMPETENCE, INEFFICIENCY, NEGLIGENCE, and DERELICTION OF DUTY. The Court emphasized the constitutional mandate to decide cases within three months. Judge Tandinco’s failure to decide or resolve a significant number of cases within the reglementary period, without requesting extensions, constituted gross inefficiency. His retirement did not extinguish his administrative liability. He was ordered to pay a FINE of P100,000.00, deductible from his retirement benefits.
2. Former Judge Alma Uy-Lampasa is GUILTY of GROSS INEFFICIENCY. The Court rejected her justifications, stating that the heavy caseload and multiple designations did not excuse her failure to request extensions of time to decide or resolve cases. As she was deemed automatically resigned from the judiciary, the Court imposed a FINE of P50,000.00, to be deducted from any accrued leave credits or withheld from any receivable from the Judiciary.
3. Clerk of Court Ronaldo C. Dioneda is GUILTY of SIMPLE NEGLECT OF DUTY. As custodian of court records, he failed to adequately explain the non-presentation of case records during the audit and to ensure the proper maintenance and updating of court dockets and records. He was ordered to pay a FINE of P5,000.00, with a stern warning.