A.M. No. RTJ-12-2334; November 14, 2012
ERNESTO HEBRON, Complainant, vs. JUDGE MATIAS M. GARCIA II, Regional Trial Court, Branch 19, Bacoor City, Cavite, Respondent.

FACTS

Complainant Ernesto Hebron filed an administrative complaint against Judge Matias M. Garcia II for gross ignorance of the law, incompetence, abuse of authority, and abuse of discretion. The complaint stemmed from the judge’s handling of a petition for certiorari (BSC No. 2009-02) filed by Aladin Simundac, seeking to suspend a criminal case for falsification Hebron had initiated. Hebron alleged bias, citing the judge’s prior dismissal of a related civil case, and procedural errors in issuing a preliminary injunction. Hebron also filed a motion for reconsideration of the injunction order dated September 18, 2009.
Judge Garcia failed to resolve this motion for reconsideration for an unreasonable period. Hebron highlighted the delay of over one year and nine months, despite follow-up motions. In his defense, Judge Garcia admitted the inadvertent delay, attributing it to an overwhelming caseload of approximately 3,788 pending cases and his court’s designation as a pilot court for a case reduction program, which consumed several months of judicial time.

ISSUE

Whether Judge Matias M. Garcia II is administratively liable for undue delay in resolving a pending motion for reconsideration.

RULING

Yes, Judge Garcia is administratively liable for undue delay. The Supreme Court emphasized that the prompt disposition of court business is a constitutional mandate and a core duty under the Code of Judicial Conduct. While judges may not be disciplined for errors in the exercise of adjudicative functions absent proof of bad faith or malice, failure to decide cases or resolve pending incidents within the required period constitutes a less serious charge under Section 9, Rule 140 of the Revised Rules of Court.
The Court found Judge Garcia’s explanation—attributing the delay to heavy caseload and court programs—insufficient to exonerate him. Administrative liability for delay is not negated by heavy workload; at most, it serves only to mitigate the penalty. The Court cited jurisprudence establishing that a judge’s duty to manage the court’s docket includes requesting extensions if necessary, a step Judge Garcia failed to take. However, the Court considered mitigating factors: the delay involved a single motion, it was his first administrative offense, there was no showing of bad faith, and his caseload was exceptionally high. Consequently, while guilty of undue delay, the recommended fine was reduced from P5,000.00 to P2,000.00. Judge Garcia was sternly warned that a repetition would be dealt with more severely. The other charges pertaining to his judicial adjudication were dismissed.