A.M. No. RTJ-98-1412. July 19, 2000. OFFICE OF THE COURT ADMINISTRATOR, petitioner, vs. JUDGE PANFILO S. SALVA, RTC, Branch 47, Puerto Princesa City [Formerly of MTCC, Puerto Princesa City] and JUDGE FERNANDO R. GOMEZ, JR., MTC, Brooke’s Point, Palawan, respondents.
FACTS

The Office of the Court Administrator (OCA) conducted a judicial audit of the Municipal Trial Court in Cities (MTCC) in Puerto Princesa City. The audit focused on cases submitted for decision inherited by the newly appointed judge, Judge Jocelyn S. Dilig, from her predecessors: Judges Ofelia Abueg Sta. Maria, Panfilo S. Salva, and Fernando R. Gomez, Jr. The audit team discovered 75 cases left undecided or unresolved. Specifically, 64 cases were left by Judges Sta. Maria and Salva, and 11 cases were submitted during Judge Gomez’s tenure as acting presiding judge. The audit also found irregularities, including missing case records and unreported cases in monthly reports.
The Supreme Court required Judges Salva and Gomez to comment on their failure to decide the cases within the 90-day reglementary period. Judge Salva admitted his failure, citing a heavy caseload and health issues, but argued some cases were not yet submitted for decision during his tenure. Judge Gomez explained his designation as acting judge was temporary and that he prioritized cases in his own court, requesting an extension to decide the inherited cases.

ISSUE

Whether respondents Judges Panfilo S. Salva and Fernando R. Gomez, Jr. are administratively liable for their failure to decide cases within the mandatory 90-day period.

RULING

Yes, both judges are administratively liable. The constitutional mandate and the Code of Judicial Conduct require judges to decide cases within 90 days from submission. Failure to do so constitutes gross inefficiency and warrants administrative sanction. The Court rejected Judge Salva’s excuses of heavy caseload and health problems, emphasizing that these do not absolve a judge from the duty to request extensions from the Court if more time is genuinely needed. His admission of failure, without having sought such an extension, confirms the violation.
For Judge Gomez, the Court found his explanation unpersuasive. His designation as acting judge carried the full responsibility of a presiding judge, including the duty to decide cases within the period. His claim of prioritizing his home court does not excuse the delay, as he should have managed his time or officially sought relief. The Court considered his subsequent compliance in deciding the cases as a mitigating factor but not an exoneration.
Consequently, Judge Panfilo S. Salva was FINED P20,000.00. Judge Fernando R. Gomez, Jr. was FINED P5,000.00, with a stern warning. The Court underscored that the timely disposition of cases is a paramount judicial duty, and any delay, without an authorized extension, undermines public confidence in the administration of justice.