G.R. No. A.M. No. RTJ-16-2463 (Formerly A.M. No. 16-05-110-RTC). July 27, 2021.
Office of the Court Administrator, complainant, vs. Judge Candelario V. Gonzales, Regional Trial Court, Branch 45, Bais City, respondent.

FACTS

A judicial audit was conducted from November 24 to 26, 2014, at the Regional Trial Court, Branch 45, Bais City, presided by Judge Candelario V. Gonzales. The audit revealed a total caseload of 962 active cases. Specific adverse findings included: (a) out of 100 criminal cases submitted to Judge Gonzales for decision, 61 were decided beyond the reglementary period; (b) Judge Gonzales inhibited himself from several criminal cases that had already been submitted for decision; (c) Judge Gonzales had 54 criminal and 17 civil cases with unresolved motions; (d) he made no requests for extension of time to decide cases or resolve motions; (e) his Certificates of Service from January 2013 to December 2014 falsely indicated there were no cases submitted for decision or pending motions, contrary to data from the Statistical Reports Division; (f) case records were disorganized; (g) there was no actual physical inventory of pending cases; (h) documents lacked time and date of receipt; (i) court reports were not updated; and (j) docket books were not updated. The Office of the Court Administrator (OCA) directed Judge Gonzales to explain these deficiencies. In his defense, Judge Gonzales cited health problems (angioplasty, angiogram, and hospitalization for intestinal amoebiasis in 2013), health issues of his court stenographers, and claimed he had decided almost all submitted cases by March 2015. He also stated he sought relief for his caseload but received no response. The OCA found his explanations insufficient.

ISSUE

Whether Judge Candelario V. Gonzales should be held administratively liable for Gross Dereliction of Duty, Gross Inefficiency, Gross Incompetence, and Gross Dishonesty due to undue delay in deciding cases and resolving motions, failure to request extensions, falsification of Certificates of Service, and poor court management.

RULING

Yes. Judge Gonzales is guilty of Gross Inefficiency and Gross Dishonesty. The Court emphasized the constitutional mandate to decide cases within three months from submission. Judge Gonzales’s failure to decide 61 criminal cases on time, his failure to resolve numerous motions, and his failure to request extensions constituted gross inefficiency. His health issues and staff problems were not sufficient excuses, as he failed to duly inform the Court or request extensions. His act of certifying in his Certificates of Service that he had no pending cases or motions, when in fact he had a significant backlog, constituted gross dishonesty. This falsification was a serious transgression undermining judicial integrity. The Court also noted his poor administrative supervision, resulting in disorganized records and failure to maintain proper docket books. Considering the gravity of the offenses, which included dishonesty, and following prevailing jurisprudence, the penalty of dismissal from service was appropriate. However, as Judge Gonzales had already been dismissed in a separate administrative case (A.M. No. RTJ-19-2549), the Court instead imposed a fine of One Hundred Thousand Pesos (P100,000.00) to be deducted from his accrued leave credits, with a stern warning that a repetition would be dealt with more severely.