G.R. No. RTJ-06-1979. March 14, 2007.
NAPOLEON CAGAS, Complainant, vs. JUDGE ROSARIO B. TORRECAMPO, Presiding Judge, Regional Trial Court, Branch 33, Pili, Camarines Sur, Respondent.

FACTS

Complainant Napoleon Cagas, brother of an accused, charged respondent Judge Rosario B. Torrecampo with serious neglect of duty, falsification, incompetence, knowingly rendering an unjust judgment, and infidelity to ethical canons. The charges stemmed from Criminal Case Nos. P-2196 to P-2201 for murder. The cases were submitted for decision in June 2000. For over four years, no decision was rendered, during which one accused died in incarceration. The remaining accused filed a Motion to Dismiss on January 11, 2005, invoking their right to a speedy disposition. The motion was set for hearing on January 19, 2005. However, counsel received an order setting the promulgation of a conviction decision for January 18, 2005, one day before the motion’s hearing, effectively rendering it moot. Complainant alleged the decision was based merely on an old bail hearing resolution and failed to account for the lengthy trial delays.
In her Comment, respondent judge attributed the delay to severe and recurring health problems afflicting her and her family from 2001 to 2004, including hypertension, pulmonary Koch’s disease, and an enlarged thyroid gland, which required hospitalization and leaves of absence. She argued she had requested extensions from the Court, consistently reported the cases as pending, and thus could not be liable for falsification. She maintained she diligently studied the voluminous records and that her decision, which adopted findings from a prior Court of Appeals resolution on bail, was not unjustly rendered.

ISSUE

Whether respondent Judge Rosario B. Torrecampo is administratively liable for the undue delay in rendering a decision in the subject criminal cases.

RULING

Yes, respondent is administratively liable for undue delay. The Court found that the cases were submitted for decision on December 8, 2000, and the decision was promulgated only on January 18, 2005, a delay of over four years beyond the 90-day reglementary period mandated by the Constitution. While the Court acknowledged respondent’s health issues as mitigating circumstances, it ruled that these do not entirely absolve her of liability. Judges have a paramount duty to decide cases promptly and to request extensions of time if necessary. Chronic health problems, while understandable, necessitate more proactive measures, such as requesting an extended leave or considering retirement, to avoid prejudice to parties. The Court noted respondent had a prior administrative sanction for similar delay.
The charges of knowingly rendering an unjust judgment, falsification, and incompetence were dismissed for lack of merit. An unjust judgment requires proof of deliberate malice, which was not substantiated. The alleged falsification pertained to monthly certifications of no pending cases, but the record showed the cases were properly reported as pending. The adoption of prior bail hearing findings, while potentially a judicial error, is not gross incompetence warranting administrative sanction absent proof of bad faith. However, the undue delay itself constitutes a less serious charge under the Rules of Court. Considering the mitigating health circumstances and prior sanction, the Court imposed a fine of Ten Thousand Pesos (P10,000.00) with a stern warning against repetition.