AM SCc 01 7; (March, 2002) (Digest)
G.R. No. A.M. No. SCC-01-7. March 12, 2002.
Hadja Thittie M. Arap, complainant, vs. Judge Amir Mustafa, respondent.
FACTS
Complainant Hadja Thittie M. Arap filed an administrative complaint against Judge Amir Mustafa, presiding judge of the First Shari’a Circuit Court of Jolo, Sulu, for gross neglect of duty, ignorance of the law, and conduct unbecoming a judge. The complaint alleged that the respondent judge failed to resolve Criminal Case No. 96-01, which was filed on April 15, 1996, and submitted for resolution in the same year, but remained unresolved. The respondent judge, in his Comment, denied the allegations. He explained that he had motu proprio dismissed the case on June 11, 1996, but the Shari’a District Court remanded it for preliminary investigation. The accused was arraigned on August 4, 1997, trial ensued, and the case was submitted for resolution in October 1998. The respondent judge admitted he rendered a Decision on January 25, 2000, and promulgated it on March 1, 2000. He justified the delay by stating he found it difficult to reconcile the provisions of P.D. 1083 with the Qur’an and the Hadith, requiring time for reflection and consultation. He also contended that his court had a heavy caseload, with 114 cases in 1999, 83 of which were terminated that year.
ISSUE
Whether respondent Judge Amir Mustafa is administratively liable for undue delay in rendering a decision in Criminal Case No. 96-01.
RULING
Yes, the respondent judge is administratively liable for gross inefficiency. The Constitution mandates lower courts to decide cases within three months after submission for decision. The respondent judge failed to decide Criminal Case No. 96-01 within this period, as it was submitted in October 1998 but decided only in January 2000. He did not request an extension from the Supreme Court to justify the delay. His explanation—difficulty in reconciling legal sources—does not excuse the delay, as judges must inform the Court of such difficulties and seek an extension. The delay contravenes Canon 3, Rule 3.05 of the Code of Judicial Conduct, which requires judges to dispose of court business promptly. The Court adopted the Office of the Court Administrator’s recommendation to impose a fine of P5,000.00, considering it was the respondent’s first offense in nearly nine years of service. He was warned that repetition would be dealt with more severely.