AM RTJ 07 2067; (June, 2008) (Digest)
A.M. No. RTJ-07-2067. June 18, 2008. NILO JAY MINA, complainant, vs. JUDGE JESUS B. MUPAS, Regional Trial Court, Branch 112, Pasay City, respondent.
FACTS
Complainant Nilo Jay Mina, the plaintiff in a civil case pending before respondent Judge Jesus B. Mupas, filed an administrative complaint for gross inefficiency, dereliction of duty, and manifest partiality. The complaint alleged that Judge Mupas failed to resolve complainant’s “Urgent Motion to Declare All Defendants in Default” within the 90-day reglementary period. The motion was filed in May 2006, but remained unresolved for over seven months, prompting the complaint in January 2007.
In his Comment, respondent judge admitted the delay but explained that he had actually resolved the subject motion, along with two other pending motions, in an Order dated December 18, 2006. He attributed the oversight in service of copies to inadvertence. He further argued that the delay was excusable, citing his heavy workload from handling two court branches simultaneously, and claimed the complaint was filed without prior verification, constituting harassment. The Office of the Court Administrator (OCA) and the Investigating Justice found respondent liable for the delay but found no evidence to support the charge of partiality.
ISSUE
Whether respondent Judge Jesus B. Mupas is administratively liable for failing to resolve pending motions within the constitutionally mandated period.
RULING
Yes, respondent judge is administratively liable for gross inefficiency. The Constitution mandates lower courts to decide or resolve matters within three months from submission. This duty is reinforced by the Code of Judicial Conduct, which requires judges to dispose of court business promptly. The Court emphasized that the right to a speedy disposition of cases is fundamental; any delay undermines public faith in the judiciary.
Respondent’s admission of delay is conclusive. His defense of heavy workload due to an additional court assignment is not a valid excuse. The Court consistently holds that while heavy caseload may explain a delay, it does not exonerate a judge from liability. Judges are required to manage their dockets efficiently and, if necessary, request extensions from the Court to comply with periods. Respondent’s failure to do so constitutes gross inefficiency. The charge of partiality was correctly dismissed for lack of evidence. Considering the delay of approximately seven to eight months and respondent’s previous administrative sanction, the Court found the recommended fine of P10,000.00 appropriate, with a stern warning that a repetition would be dealt with more severely.