A.M. No. RTJ-02-1676; August 28, 2003
Office of the Court Administrator vs. Judge Guillermo R. Andaya

FACTS

A 1997 judicial audit of the Regional Trial Court of Lucena City, Branches 53 and 54, then presided over by respondent Judge Guillermo R. Andaya, revealed numerous unresolved cases and motions. For Branch 53, there were 26 cases submitted for decision beyond the 90-day reglementary period, 8 undecided appealed cases, 3 criminal cases awaiting promulgation, and 27 cases with unresolved motions. For Branch 54, where he also served as acting judge, there were 13 undecided cases, 3 undecided appealed cases, 2 criminal cases for promulgation, and 11 cases with unresolved motions. The Court, in a 1998 resolution, directed Judge Andaya to decide these matters within four months and to explain his failure to do so and his certification in his September 1997 Certificate of Service that all cases and motions had been determined.
Subsequent audits and reports from 1999 to 2001 showed persistent non-compliance. Despite repeated directives and extensions granted by the Court, Judge Andaya took over two and a half years to fully dispose of the backlog. He cited presiding over two branches and handling heinous crimes cases as reasons for the delay and pleaded for leniency regarding the inaccurate certification.

ISSUE

Whether Judge Andaya is administratively liable for undue delay in deciding cases and resolving motions, and for making an untruthful statement in his Certificate of Service.

RULING

Yes, Judge Andaya is administratively liable. The Court found his excuses for the delay—presiding over two branches and trying heinous crimes—unavailing. These circumstances do not exempt him from liability but merely highlight the need to request formal extensions from the Court, which he failed to do promptly. His inefficiency, demonstrated by the initial backlog of 50 undecided cases, 38 unresolved motions, and 5 un-promulgated decisions, and the protracted period required to clear it, constitutes a violation of Rule 3.05, Canon 3 of the Code of Judicial Conduct and the constitutional mandate for speedy case disposition.
Furthermore, his certification in his September 1997 Certificate of Service was clearly untruthful, given the audit findings. This act compromised the integrity of a document essential to judicial accountability. Both offenses are classified as less serious charges under A.M. No. 01-8-10-SC. Considering the gravity of the delay, the number of cases involved, and the commission of two separate infractions, the Court imposed a fine of Twenty Thousand Pesos (₱20,000) with a stern warning against repetition.