A.M. No. RTJ-00-1599. November 15, 2001. TRANQUILINO F. MERIS, complainant, vs. JUDGE FLORENTINO M. ALUMBRES, Presiding Judge, Regional Trial Court, Las Piñas City, Branch 255, respondent.
FACTS

Complainant Tranquilino F. Meris, counsel for the plaintiff in an unlawful detainer case, filed an administrative complaint against Judge Florentino M. Alumbres for inefficiency due to undue delay in deciding Civil Case No. 96-0256. The case was submitted for decision on March 11, 1997. Despite complainant filing several ex parte motions for resolution in July, August, and October 1997, no decision was rendered. The complaint was filed with the Office of the Court Administrator on November 12, 1998.
Respondent judge, in his comment, explained that the case records were lost in March 1997 when a court personnel misplaced the folder after a follow-up inquiry. The loss was not reported to him, and court staff attempted to reconstruct the records without his knowledge. He claimed he only learned of the case’s status in mid-February 1999 when the reconstructed records were placed on his desk. He subsequently promulgated the decision on February 24, 1999. Respondent highlighted his good performance record for 1998 and noted the original records were later recovered.

ISSUE

Whether respondent judge is administratively liable for inefficiency and undue delay in deciding a case.

RULING

Yes, respondent judge is administratively liable. The Supreme Court found inefficiency caused the nearly two-year delay in deciding the case, far exceeding the 90-day constitutional mandate. While the loss of records by court personnel was a contributing factor, respondent judge bears ultimate administrative responsibility for the proper management and supervision of his court. The Code of Judicial Conduct requires judges to diligently discharge administrative responsibilities and supervise court personnel to ensure prompt and efficient court business.
The Court emphasized that due diligence in administrative supervision would have alerted respondent to the pending unresolved motions and the missing records much earlier. His failure to discover the loss and ensure timely reconstruction or resolution of the case constituted a breach of his administrative duties. His good performance in other cases does not exonerate him from liability in this specific instance. The delay prejudiced the litigants and undermined public confidence in the judiciary. Accordingly, the Court imposed a fine of Five Thousand Pesos (P5,000.00) with a stern warning.