G.R. No. 94 -10-96-MTCC EN BANC, September 5, 1995
REPORT ON THE JUDICIAL AUDIT AND PHYSICAL INVENTORY OF THE RECORDS OF CASES IN MTCC-BR. 2, BATANGAS CITY.

FACTS

A judicial audit of the Municipal Trial Court in Cities (MTCC), Branch 2, Batangas City, was conducted on August 24, 1994. The audit team arrived at 8:30 a.m. but found the court closed. It only opened past 9:00 a.m., with personnel arriving late. The audit revealed nineteen (19) cases submitted for decision that remained undecided beyond the 90-day reglementary period. The Clerk of Court could only produce six case records, explaining the other thirteen were with the presiding judge, Judge Francisco D. Sulit, who was attending a seminar. The Office of the Court Administrator (OCA) recommended disciplinary action against Judge Sulit for gross inefficiency and against court employees for failure to observe office hours.
In his explanation, Judge Sulit impliedly admitted the delay but cited mitigating circumstances: missing or untranscribed stenographic notes from trials that began before his assumption of office, a prolonged lack of a stenographer due to leave and denied requests, the Branch Clerk of Court’s long leave, the loss of his personal notes, and a series of family deaths that affected his work. He also highlighted his long government service and high case disposal rate. The court employees denied being late, but their denial was contradicted by affidavits from other court personnel corroborating the audit team’s report.

ISSUE

Whether Judge Sulit and the court personnel of MTCC Branch 2, Batangas City, should be held administratively liable.

RULING

Yes, both Judge Sulit and the court personnel are administratively liable. The Court found Judge Sulit guilty of serious misconduct and gross inefficiency for failing to decide nineteen cases within the mandatory 90-day period under the Constitution and the Judiciary Act. While the Court acknowledged his cited mitigating circumstances—such as administrative difficulties, family tragedies, and his otherwise satisfactory record of case disposal—these do not absolve him of liability. The duty to decide cases promptly is mandatory. Applying precedents, the failure to decide even a single case within the period warrants a penalty. Considering the mitigating factors and that this was his first offense, a fine of Fifteen Thousand Pesos (P15,000.00) was deemed appropriate.
Regarding the court personnel, the Court upheld the audit team’s finding that they reported for work late on the day of the audit. Their collective denial could not prevail over the positive and corroborated report of the audit team and the affidavits of other court employees. Their tardiness constituted neglect of duty. However, as a first offense, they were merely reprimanded and sternly warned to observe office hours diligently, with a warning that repetition would be dealt with more severely.