AM RTJ 00 1582; (September, 2000) (Digest)
A.M. No. RTJ-00-1582. September 4, 2000. COB C. DE LA CRUZ, complainant, vs. JUDGE RODOLFO M. SERRANO, RTC-BR. 17 KIDAPAWAN, NORTH COTABATO, respondent.
FACTS
Complainant Cob C. de la Cruz filed an administrative case against Judge Rodolfo M. Serrano for dishonesty, falsehood, and negligence in relation to Civil Case No. 908. The complainant alleged that the judge decided the case with partiality by suppressing evidence, inventing a municipal resolution, and misconstruing an exhibit. He also charged the judge with undue delay, noting that it took one year and five months to render a decision, far exceeding the constitutional three-month reglementary period.
In his Comment, respondent Judge Serrano prayed for the dismissal of the complaint, arguing that the charges pertaining to the merits of the decision were proper for appeal, not an administrative case. He attributed the delay in disposition to the complainant’s own requests for postponements and explained that he gave preferential attention to criminal cases involving detention prisoners and heinous crimes.
ISSUE
Whether respondent Judge Rodolfo M. Serrano is administratively liable for the charges against him.
RULING
The Supreme Court found respondent Judge administratively liable only for undue delay in rendering a decision. The charges of dishonesty, falsehood, partiality, and negligence in the appreciation of evidence are judicial in nature. These pertain to the judge’s exercise of adjudicative functions and are proper subjects for appeal, not administrative discipline, especially since the decision had already been affirmed by the Court of Appeals. An administrative complaint is not the correct remedy for correcting a judge’s alleged errors of judgment, absent proof of bad faith, malice, or corrupt purpose.
However, the charge of delay is separate and administrative. The Constitution mandates that lower courts decide cases within three months from submission. The judge’s failure to decide Civil Case No. 908 within this period, taking one year and five months, constitutes gross inefficiency and neglect of duty. His justifications—postponements by counsel and prioritizing criminal cases—are unacceptable. The reglementary period is mandatory, and giving preference to certain cases does not excuse the failure to decide others within the time frame. Delay in case disposition denies justice and erodes public confidence in the judiciary.
The Court modified the Office of the Court Administrator’s recommendation. While liable, the recommended fine of Ten Thousand Pesos (₱10,000.00) was deemed too harsh. Respondent Judge Rodolfo M. Serrano was FINED Five Thousand Pesos (₱5,000.00) with a STERN WARNING.