AM RTJ 05 1941; (April, 2006) (Digest)
A.M. No. RTJ-05-1941. April 25, 2006. OFFICE OF THE COURT ADMINISTRATOR, Complainant, vs. JUDGE LOURDES M. GARCIA-BLANCO and ATTY. LOLITA R. MERCADO, Branch Clerk of Court, both of the Regional Trial Court, Carigara, Leyte, Branch 36, Respondents.
FACTS
A judicial audit of the Regional Trial Court, Branch 36, Carigara, Leyte, was conducted on November 17, 2004, while it was presided over by Judge Lourdes M. Garcia-Blanco. The audit report revealed significant delays in case disposition. Of ten (10) cases submitted for decision, three (3) civil cases remained undecided beyond the mandatory 90-day reglementary period. Furthermore, motions submitted for resolution in eleven (11) out of nineteen (19) cases were unresolved beyond the required period. The audit also identified six (6) cases with no initial action and seventy-two (72) cases that had not been acted upon for a considerable time, indicating a general state of inactivity.
The Office of the Court Administrator (OCA) directed Judge Blanco to explain the delays and to decide or resolve the pending matters. In her compliance, Judge Blanco attributed the backlog to her heavy caseload, health issues, and the alleged inefficiency of her staff, particularly Branch Clerk of Court Atty. Lolita R. Mercado. She claimed to have decided or resolved most of the flagged cases upon receiving the directive. Atty. Mercado, for her part, denied the allegations of inefficiency and shifted responsibility to the judge and other court personnel.
ISSUE
Whether respondents Judge Lourdes M. Garcia-Blanco and Atty. Lolita R. Mercado are administratively liable for the failure to decide cases and resolve motions within the reglementary period, and for the general inactivity of cases in their court.
RULING
Yes, both respondents are administratively liable. The Court found Judge Blanco guilty of Gross Inefficiency. Judges have a sworn duty to administer justice promptly. The Constitution and the Rules of Court mandate that cases be decided within 90 days from submission. Failure to observe this period constitutes gross inefficiency and warrants administrative sanction. Judge Blancoβs excuses of heavy caseload and health problems were insufficient; she should have requested extensions from the Court. Her claim of staff inefficiency does not exonerate her, as the primary responsibility for case management rests with the judge. Considering it was her first offense, she was fined Fifteen Thousand Pesos (P15,000.00), deductible from her retirement benefits.
Atty. Mercado was found guilty of Neglect of Duty as Branch Clerk of Court. As an officer of the court and part of the judiciary, she is charged with the duty to assist in the speedy disposition of justice. Her failure to ensure the proper tracking and timely submission of cases for resolution contributed to the courtβs backlog. She was fined One Thousand Pesos (P1,000.00) with a stern warning.
