AM RTJ 00 1595; (October, 2000) (Digest)
G.R. No. RTJ-00-1595; October 24, 2000
LUZ CADAUAN and CLARO CADAUAN, complainants, vs. JUDGE ARTEMIO R. ALIVIA, REGIONAL TRIAL COURT OF CAUAYAN, ISABELA, BRANCH 19, respondent.
FACTS
Complainants Luz and Claro Cadauan were parties in Special Civil Action No. Br. 19-83 for Partition with Liquidation, assigned to respondent Judge Artemio R. Alivia. The case was submitted for decision on October 21, 1998. In a complaint dated June 30, 1999, they charged the judge with dishonesty and grave misconduct for certifying he had disposed of cases within 90 days when their case remained undecided, allegedly depriving them of property possession. Respondent Judge, in his Comment, admitted the delay but justified it by citing his voluminous workload as a presiding judge of a Special Crimes Court designated to handle heinous crimes, to which he gave priority. He also denied signing the specific certificate of service attached to the complaint. The case was eventually decided on September 9, 1999, nearly eleven months after submission. Respondent Judge retired from the judiciary on November 14, 1999.
ISSUE
Whether respondent Judge Artemio R. Alivia is administratively liable for his failure to decide the civil case within the mandatory 90-day reglementary period.
RULING
Yes, respondent Judge is administratively liable for gross inefficiency. The Supreme Court emphasized that Rule 3.05 of the Code of Judicial Conduct mandates judges to dispose of court business promptly and decide cases within required periods. The constitutional right to a speedy disposition of cases is paramount. The Court found that the civil case was submitted for decision on October 21, 1998, and judgment was rendered only on September 9, 1999, a delay of almost eleven months, well beyond the 90-day period. Respondent’s admission of the delay and his justification of a heavy workload, including handling heinous crimes, were deemed insufficient excuses. The Court consistently holds that failure to decide within the reglementary period constitutes gross inefficiency and neglect of duty, undermining public faith in the judiciary. His subsequent retirement does not absolve him of liability. However, the charge of dishonesty was not substantiated by complainants. Accordingly, the Court adopted the Office of the Court Administrator’s recommendation and imposed a fine of Five Thousand Pesos (P5,000.00) to be deducted from his retirement benefits.