A.M. No. RTJ-04-1821 ; August 12, 2004
JOSE E. FERNANDEZ, complainant, vs. JUDGE JAIME T. HAMOY, Regional Trial Court, Branch 130, Caloocan City, respondent.

FACTS

Complainant Jose E. Fernandez, counsel in two civil cases pending before the Regional Trial Court (RTC) of Zamboanga City, Branch 15, then presided by respondent Judge Jaime T. Hamoy, filed an administrative complaint for Abuse of Authority, Dereliction of Duty, and Violation of Rule 3.05 of the Code of Judicial Conduct. The complaint stemmed from Judge Hamoy’s failure to render judgment in the two cases for over ten years. After his transfer to the RTC of Caloocan City, respondent brought the records of the unresolved cases to his new station without clearance. Following a letter from complainant to the Court Administrator, the Office of the Court Administrator (OCA) repeatedly directed respondent to comment on the complaint. Judge Hamoy ignored several directives and tracers, finally submitting an explanation only after a show-cause order was issued.

ISSUE

Whether respondent Judge Jaime T. Hamoy is administratively liable for gross inefficiency and dereliction of duty.

RULING

Yes, respondent Judge is administratively liable. The Supreme Court found him guilty of gross inefficiency, dereliction of duty, and violation of Canon 3, Rule 3.05 of the Code of Judicial Conduct. The legal logic is anchored on the fundamental judicial duty to decide cases promptly and to manage court affairs efficiently. Respondent’s excuses—forgetting to comment, misplaced records due to staff error, and a congested docket—were deemed unacceptable. A judge bears ultimate administrative responsibility for organizing and supervising court personnel to ensure prompt dispatch of business; the inefficiency of staff does not absolve the judge. Crucially, respondent failed to decide the cases within the reglementary period and did not seek any extension before its expiration. His act of transferring case records to a new station without OCA clearance or notice to parties compounded the delay and created suspicion. The Court emphasized that undue delay undermines public faith in the judiciary. Considering the 13-year delay, his disregard of OCA directives, and a prior admonition for similar inefficiency, his collective transgressions demonstrated unfitness for judicial office. The penalty of dismissal, with forfeiture of retirement benefits and disqualification from government re-employment, was imposed to uphold judicial accountability and integrity.