AM RTJ 07 2057; (August, 2007) (Digest)
A.M. No. RTJ-07-2057; August 7, 2007
ROSALINA GALANZA, Complainant, vs. Judge HENRY J. TROCINO, RTC, Branch 62, Bago City, Respondent.
FACTS
Complainant Rosalina Galanza, mother of the victims, filed an administrative complaint against Judge Henry J. Trocino for gross inefficiency, serious misconduct, and undue delay in deciding Criminal Case Nos. 796 and 810 for murder and frustrated homicide. The cases, jointly tried, were submitted for decision on January 25, 2000. From August 2000 to November 2002, Galanza filed seven motions for early resolution, followed by a letter to the Chief Justice in September 2005, all due to the judge’s inaction.
Judge Trocino, in his defense, claimed he assumed office in July 1999 and inherited the cases from previous judges. He argued he could not decide the cases because several transcripts of stenographic notes (TSNs) from hearings between 1992 and 1998 were missing, despite his directives to the stenographers. He asserted the reglementary period had not commenced due to the incomplete records and cited a prior administrative case where a judge was absolved under similar circumstances.
ISSUE
Whether Judge Henry J. Trocino is administratively liable for undue delay in rendering judgment in Criminal Case Nos. 796 and 810.
RULING
Yes, Judge Trocino is administratively liable. The Supreme Court rejected his defense, emphasizing that judges have a constitutional and statutory duty to decide cases within three months from submission under Section 15(1), Article VIII of the Constitution and Rule 3.05 of the Code of Judicial Conduct. The Court clarified that the reglementary period begins upon submission of the last required pleading or memorandum, not upon the completion of TSNs. A judge is mandated to take proactive steps to obtain missing transcripts and cannot passively await compliance from court personnel. His reliance on a prior case was misplaced, as the factual circumstances differed; here, the case was submitted to him, and he failed to exhaust all administrative remedies to secure the records or request an extension. His inaction for over five years constituted gross inefficiency, undermining public confidence in the judiciary. The Court modified the OCA’s recommendation and imposed a fine of Twenty Thousand Pesos (₱20,000.00), deductible from his retirement benefits, for undue delay in rendering a decision.