A.M. No. RTJ-16-2479, December 13, 2017
Daniel G. Fajardo vs. Judge Antonio M. Natino, Regional Trial Court, Branch 26, Iloilo City

FACTS

Complainant Daniel G. Fajardo, representing Panay News, Inc., filed an administrative complaint against Judge Antonio M. Natino for alleged violations in handling two civil cases. In Civil Case No. 20225, submitted for decision on January 23, 2007, Judge Natino rendered the decision only on April 21, 2010, exceeding the 90-day constitutional and statutory period by over three years. The decision was further released four months later, on August 17, 2010. Fajardo also charged the judge with falsifying his Certificates of Service by collecting his salary despite this unresolved case.
Regarding Civil Case No. 07-29298, Fajardo alleged Judge Natino failed to resolve a Motion to Show Cause for contempt and improperly entertained a prohibited second motion for reconsideration. The complainant theorized these delays and procedural lapses were maneuvers by the judge to gain leverage for a personal financial request from a party connected to the cases.

ISSUE

Whether Judge Antonio M. Natino is administratively liable for the charges against him.

RULING

The Supreme Court found Judge Natino guilty only of undue delay in rendering a decision in Civil Case No. 20225. The Court emphasized that the 90-day period for deciding cases is mandatory. Judge Natino’s justifications—including his duties as Executive Judge, staff resignation, city hall renovation, and power outages—were deemed insufficient to excuse a delay exceeding three years. The Court ruled that such administrative burdens and incidental inconveniences are ordinary occurrences that a judge must manage efficiently, and they do not absolve the failure to decide within the reglementary period.
However, the Court dismissed the other charges for lack of substantial evidence. The allegation of falsifying Certificates of Service was not proven, as mere delay does not automatically equate to falsification. The charges concerning the Motion for Contempt and the second motion for reconsideration in Civil Case No. 07-29298 were also dismissed, as the complainant failed to appear during the investigation to substantiate these claims, and Judge Natino’s explanations were deemed satisfactory.
Considering it was his first offense and his over 33 years of service prior to retirement, the Court imposed a fine of Ten Thousand Pesos (₱10,000.00) for the less serious charge of undue delay. The amount was ordered deducted from his withheld retirement benefits.