G.R. No. RTJ-00-1526. June 3, 2004
OFFICE OF THE COURT ADMINISTRATOR, complainant, vs. JUDGE FRANKLIN A. VILLEGAS, respondent.

FACTS

This administrative case originated from an undated letter-complaint filed by Dr. Fe Yabut, received by the Office of the Court Administrator (OCA) on January 5, 1999. Dr. Yabut complained of the inordinate delay in the disposition of Civil Case No. 1576, a reconveyance case filed in 1976, which had been pending before respondent Judge Franklin A. Villegas of the Regional Trial Court (RTC) of Pagadian City, Branch 19, since he assumed the case on August 22, 1984. After nearly 15 years under his helm, the trial remained unfinished and no decision had been rendered.
Acting on the complaint, the OCA, through then Court Administrator Alfredo L. Benipayo, twice required Judge Villegas to comment on the allegations. He ignored these directives. Consequently, the Court en banc ordered him to answer and show cause. He still failed to comply, leading the Court to impose fines of ₱1,000 and later ₱2,000 for his continued defiance. Only in March 2001 did he respond, citing deteriorating eyesight since the late 1980s, and he eventually filed his comment in December 2003. He attributed the case delay to party-initiated postponements, a court stenographer’s death affecting transcript preparation, and ongoing settlement negotiations.

ISSUE

Whether respondent Judge Franklin A. Villegas is administratively liable for undue delay in rendering a decision and for failure to comply with the directives of the OCA and the Supreme Court.

RULING

Yes, the Court found Judge Villegas guilty of two less serious offenses. The legal logic is anchored on the constitutional and canonical mandate for judges to dispose of court business promptly. Under Section 15(1), Article VIII of the Constitution and Canon 3, Rule 3.05 of the Code of Judicial Conduct, judges must decide cases within three months from the submission of the last pleading. Failure to do so constitutes gross inefficiency. The Court deemed Judge Villegas’s proffered justifications—postponements, stenographer issues, and settlement talks—as wholly unsatisfactory and not reasonable excuses for a delay spanning nearly two decades.
Furthermore, his repeated failure to comply with the OCA’s directives and six Court resolutions demanding his comment constituted a blatant disregard of lawful orders and administrative authority. The Court rejected his claim of visual impairment as a valid excuse, noting his admission of being assisted by clerks, which made it improbable for such serious orders to escape notice. This contumacious conduct amounted to studied defiance and insubordination. Both undue delay in rendering a decision and violation of Supreme Court rules/directives are classified as less serious charges under Section 9 of Rule 140 of the Rules of Court. Applying Section 11(B) of the same Rule, and considering he was already dismissed from service in a separate administrative case, the Court imposed a fine of ₱20,000.