AM RTJ 06 2007; (December, 2010) (Digest)
A.M. No. RTJ-06-2007; December 6, 2010
Carmen Edaño, Complainant, vs. Judge Fatima G. Asdala, Regional Trial Court, Branch 87, Quezon City, Respondent.
FACTS
Complainant Carmen Edaño was the plaintiff in a civil case for support pending before respondent Judge Fatima G. Asdala. She alleged that the judge made it appear she decided the case on March 22, 2005, but continued to rule on related motions after that date, violating the 90-day reglementary period for rendering decisions. The complainant further charged the judge with misconduct and error in denying her notice of appeal. In her comment, Judge Asdala maintained she rendered the decision on March 22, 2005, though it was mailed later. She argued any delay was not deliberate and caused no prejudice, as the complainant continued to receive support. She defended her denial of the appeal, citing that no appeal lies from an order of dismissal without prejudice, and asserted that such judicial acts are not proper subjects of an administrative case.
ISSUE
Whether respondent Judge Fatima G. Asdala is administratively liable for undue delay in rendering a decision and for other alleged judicial errors.
RULING
Yes, the respondent judge is administratively liable for undue delay. The Court agreed with the Office of the Court Administrator’s finding of guilt. Section 15, Article VIII of the Constitution mandates that cases be decided within three months from submission. This case was submitted for decision on December 9, 2004, making it due on March 9, 2005. The decision was rendered on March 22, 2005, a delay of 13 days, with no request for extension. The judge’s duty to decide promptly is mandatory, and the claim of no prejudice to the complainant is immaterial. Under Rule 140 of the Rules of Court, undue delay is a less serious offense punishable by a fine. A fine of Ten Thousand Pesos (₱10,000.00) was imposed, to be deducted from funds previously withheld from the judge.
Regarding the other charges for misconduct and rendering an erroneous decision, the Court found them without merit. The judge’s dismissal of the civil case and denial of the notice of appeal were performed in the exercise of her judicial functions. Administrative liability for judicial acts attaches only if they are tainted with fraud, dishonesty, corruption, bad faith, or gross ignorance. No such malice was proven. The proper remedy for alleged judicial errors is through judicial appeals, not an administrative complaint, absent a showing of corrupt motives.