G.R. No. RTJ-03-1785. March 10, 2005
DANILO ESPINELI, Complainant, vs. JUDGE DOLORES L. ESPAÑOL, RTC, Branch 90, Dasmariñas, Cavite, Respondent.

FACTS

Complainant Danilo Espineli was the accused in a murder case before respondent Judge Dolores L. Español. After the prosecution rested, Espineli’s counsel filed a demurrer to evidence without leave of court on March 8, 1999. The judge initially set the case for hearing on April 19, 1999. On that date, she first deemed the case submitted for decision due to the demurrer but later reopened it upon Espineli’s arrival and reset it for May 19, 1999. She eventually rendered a decision convicting Espineli on August 31, 1999. Espineli filed a motion for reconsideration on October 8, 1999. As of June 19, 2001, this motion remained unresolved. Espineli alleged gross inefficiency and falsification of the judge’s certificate of service for not disclosing this unresolved matter.
Respondent judge explained the delay was unintentional, attributing it to awaiting the prosecution’s comment and poor working conditions, including limited space and disorganized records. She denied dishonesty, noting no evidence was presented to support that charge.

ISSUE

Whether respondent judge is administratively liable for gross inefficiency and neglect of duty for failing to decide the case and resolve the motion for reconsideration within the reglementary periods.

RULING

Yes, respondent judge is administrarily liable for inefficiency and neglect of duty. The Supreme Court adopted the findings of the Office of the Court Administrator (OCA) but modified the recommended fine. Legally, filing a demurrer to evidence without leave of court waives the right to present evidence and submits the case for decision based on the prosecution’s evidence. The case was deemed submitted for decision no later than May 19, 1999, yet the decision was rendered only on August 31, 1999, exceeding the 90-day constitutional and statutory period. More egregiously, the motion for reconsideration remained unresolved for approximately 23 months, far beyond the mandated resolution period.
The Court rejected the judge’s excuses of awaiting prosecution comment and inadequate court facilities as flimsy and unacceptable. The Constitution and the Code of Judicial Conduct explicitly require judges to dispose of court business promptly and decide cases within required periods. Delay in the administration of justice undermines public confidence in the judiciary. The charge of dishonesty was dismissed for lack of evidence. Considering her prior administrative infraction and multiple other complaints, the Court imposed a fine of ₱11,000.00, deductible from her retirement benefits, having compulsorily retired in 2004.