G.R. No. OCA IPI NO. 14-220-CA-J, March 17, 2015
RE: COMPLAINT DATED JANUARY 28, 2014 OF WENEFREDO PARREÑO, ET AL., AGAINST HON. CELIA C. LIBREA-LEAGOGO, HON. ELIHU A. YBAÑEZ AND HON. AMY C. LAZARO-JAVIER, ASSOCIATE JUSTICES OF THE COURT OF APPEALS, RELATIVE TO CA G.R. SP NO. 108807

FACTS

Complainants Wenefredo Parreño and Ronnie Cuevas, with Joseph Denamarca, filed an administrative complaint against Court of Appeals (CA) Associate Justices Celia C. Librea-Leagogo, Elihu A. Ybañez, and Amy C. Lazaro-Javier for undue delay in rendering a decision in CA-G.R. SP No. 108807. The case originated from a protest over land titles, which was appealed to the CA. The CA’s Special 16th Division, composed of the respondent justices, issued a resolution on June 26, 2012, submitting the case for decision. The complainants alleged that from that date until the filing of their complaint on February 8, 2014, no decision had been rendered, constituting a violation of the constitutional mandate for lower collegiate courts to decide cases within 12 months.
In their comments, Justice Librea-Leagogo explained she was Chairperson of the 16th Division only from June 4 to July 5, 2012, after which the case followed Justice Ybañez, the ponente, to his new divisions. Justice Ybañez admitted the case was part of his caseload and explained the delay was due to prioritizing older cases under the Zero Backlog Project, the serious illness of a staff member assigned to the case, the subsequent resignation of a contractual lawyer he hired, and his heavy workload, though he eventually rendered the decision on February 28, 2014. Justice Lazaro-Javier stated her participation was limited to acting as a special member for the June 26, 2012 resolution due to a temporary absence, and she had no further involvement.

ISSUE

Are the respondents liable for undue delay in deciding CA-G.R. SP No. 108807?

RULING

No, the administrative complaint is without merit. The Court dismissed the complaint against all three justices.
The constitutional period for lower collegiate courts to decide cases is 12 months from submission. The case was submitted on June 26, 2012, and the decision was promulgated by the 13th Division of the CA on February 28, 2014, a delay of nearly 20 months. However, liability must be determined based on the specific role of each justice under the 2009 Internal Rules of the Court of Appeals (IRCA).
Justices Librea-Leagogo and Lazaro-Javier were not accountable. Justice Librea-Leagogo’s responsibility ended when she was transferred to another division shortly after the submission resolution. Justice Lazaro-Javier’s role was only as a temporary substitute member for the purpose of the submission resolution, in accordance with the IRCA.
For Justice Ybañez, the ponente who carried the case to the 13th Division, the Court considered the circumstances explaining the delay. While a heavy caseload is generally insufficient to excuse delay, the Court accepted his explanation as plausible and made in good faith. The delay was caused by the serious illness of a staff member, the resignation of a replacement contractual lawyer, and his efforts to prioritize older cases. There was no malice or deliberate attempt to impede justice. The Court cited precedents where delays were excused due to heavy caseloads and other valid justifications. Therefore, he was not held administratively liable.