G.R. No. RTJ-02-1737. September 9, 2004.
OFFICE OF THE COURT ADMINISTRATOR, complainant, vs. JUDGE ROBERTO S. JAVELLANA and JUDGE ABRAHAM D. CAÑA, respondents.

FACTS

An on-the-spot judicial audit was conducted in the Regional Trial Court of San Carlos City, Negros Occidental. At the time, respondent Judge Roberto S. Javellana was concurrently handling two salas: his original station, Branch 59 (a special court for heinous crimes), and Branch 57 in an acting capacity. He also served as the Executive Judge. The audit revealed that numerous cases in both branches, particularly in Branch 57 which had a heavy caseload of 559 cases, remained undecided or unresolved well beyond the 90-day reglementary period. The Court subsequently directed Judge Javellana to explain the delays and to decide or resolve the specified cases with dispatch.
In his compliance, Judge Javellana admitted the delays but cited mitigating circumstances, including his heavy workload from handling two courts and the designation of two other branches as special courts with limited jurisdictions, which led to an uneven distribution of cases. He also mentioned health issues and administrative difficulties. Separately, respondent Judge Abraham D. Caña, presiding judge of another branch, was directed to act on a specific annulment case (Civil Case No. 661) that had been pending for over four years. Judge Caña explained the delay was due to the parties’ own actions, delays from the Solicitor General’s office, and his failing health.

ISSUE

Whether respondents Judges Javellana and Caña should be held administratively liable for undue delay in rendering decisions or resolving cases.

RULING

The Court exonerated Judge Caña but found Judge Javellana administratively liable. For Judge Caña, the Court accepted his explanation as satisfactory. The delay in the annulment case was attributable to the parties and the Solicitor General’s office, and there was no proof of deliberate delay on his part, especially considering his health issues.
For Judge Javellana, the Court found his reasons insufficient to excuse the undue delay. While the Court acknowledged the mitigating circumstances of his heavy dual assignment and the uneven caseload distribution caused by the special court designations, these did not absolve him of liability. The constitutional mandate for the speedy disposition of cases is paramount. Judges are required to request extensions from the Court if they cannot comply with the reglementary period. Judge Javellana failed to do so. His health problems and administrative challenges, while noted, were not supported by formal leave applications or extension requests that would have legally justified the delays. Consequently, he was fined Twenty Thousand Pesos (₱20,000) for undue delay in rendering decisions, with a stern warning against repetition.