G.R. No. RTJ-00-1571; August 28, 2001
JESUS GUILLAS, complainant, vs. JUDGE RENATO D. MUÑEZ, Regional Trial Court, Cadiz City, Branch 60, respondent.

FACTS

Complainant Jesus Guillas, an accused detained without bail since 1993 in a murder case, charged respondent Judge Renato D. Muñez with gross negligence and undue delay in deciding Criminal Case No. 1496-S. The trial was terminated on September 4, 1997, and the judge ordered the parties to file memoranda within thirty days. The defense complied on October 22, 1997, but the prosecution failed to submit its memorandum. Despite a subsequent order granting the prosecution another thirty days, no memorandum was filed. By August 21, 1998, having been detained for nearly five years, complainant filed an ex-parte motion to decide the case, arguing the judge violated the 90-day period for rendering decisions.
In his comment, respondent judge prayed for the complaint’s dismissal. He contended the case was not submitted for decision due to the prosecution’s lack of a memorandum. He explained that a decision was ready by December 8, 1998, but was promulgated on January 14, 1999, due to the Christmas season. He also stated that in July 1998, he directed the transcription of notes because his personal notes were lost, and his legal researcher advised that no extension from the Supreme Court was needed as memoranda were expected. He further alleged the complainant’s lawyer was vindictive.

ISSUE

Whether or not respondent judge failed to decide Criminal Case No. 1496-S within the 90-day period prescribed by law.

RULING

Yes, respondent judge is administratively liable for gross inefficiency. The Supreme Court rejected his defense that the case was not submitted for decision due to the prosecution’s failure to file a memorandum. The Court emphasized Administrative Circular No. 28, which provides that a case is deemed submitted for decision upon the admission of evidence at the termination of trial. The 90-day period commences from submission 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. The filing of memoranda is discretionary and not a mandatory part of trial; it is merely an aid to the court. Non-submission constitutes a waiver, and the judge must decide based on the records and personal notes.
The Court cited Salvador v. Salamanca, ruling that judges should decide cases even if parties fail to submit memoranda. Respondent’s logic would allow indefinite delays, which is intolerable. Records show he incurred a delay of one year and one month beyond the mandated period. Failure to decide within 90 days constitutes gross inefficiency, violating Canon 3, Rule 3.05 of the Code of Judicial Conduct. Delay erodes public faith in the judiciary. Respondent never sought an extension from the Court, and the presumption was he had no excessive caseload preventing a prompt decision.
The Court adopted the Office of the Court Administrator’s recommendation. Judge Renato D. Muñez was found liable for gross inefficiency and fined Three Thousand Pesos (P3,000.00), with a stern warning that repetition would be dealt with more severely.