Re: Report On The Audit And Inventory Of Cases In Rtc Branch 55, Alaminos, Pangasinan
REITERATIONFacts
The Antecedents: The administrative matter originated from a directive to conduct an audit and physical inventory of cases pending in the Regional Trial Court, Branch 55, Alaminos, Pangasinan, presided over by Judge Vivencio A. Bantugan, due to his impending compulsory retirement. Procedural History: The audit revealed that Branch 55 had a total caseload of 324 cases. Specifically, Judge Bantugan had not taken action on 1 criminal and civil case, 2 civil cases were submitted for decision beyond the 90-day reglementary period, and 7 inherited civil cases and 14 inherited criminal cases submitted for decision remained undecided. The Deputy Court Administrator recommended a fine of P20,000.00 against Judge Bantugan for dereliction of duty due to non-action and delay in deciding cases. The Petition: The matter was referred to the Office of the Court Administrator for evaluation, report, and recommendation.
Issue(s)
Whether Judge Vivencio A. Bantugan's failure to act on and decide cases within the reglementary periods constitutes dereliction of duty and gross inefficiency. Whether the recommended fine of P20,000.00 is proper, considering the circumstances.
Ruling
The Court adopted the findings of the Deputy Court Administrator, holding Judge Bantugan liable for dereliction of duty and gross inefficiency. However, the Court reduced the fine to P10,000.00, to be deducted from his retirement benefits, considering that he was overtaken by the event of his retirement.
Ratio Decidendi
On the issue of dereliction of duty and gross inefficiency: The Court found that Judge Bantugan failed to observe Canon 3, Rule 3.05 of the Code of Judicial Conduct, which mandates that a judge should dispose of court business promptly and decide cases within the required periods. The Constitution, under Section 15(1)(2), Article VIII, requires lower courts to decide or resolve cases submitted for decision within three months from the filing of the last required pleading, brief, or memorandum. This rule is designed to prevent undue delay in the administration of justice, as "justice delayed is justice denied." The Court emphasized that delay in the disposition of cases erodes public faith in the judiciary. Judge Bantugan's failure to decide the assigned cases within the required period was not excused, and such failure constitutes gross inefficiency. Rendering decisions beyond the prescribed ninety (90) days from submission constitutes serious misconduct detrimental to the honor and integrity of his office and in derogation of the speedy administration of justice. The Court reiterated that for the guidance of judges, cases must be decided within the three-month period, and failure to do so is a ground for administrative sanction. On the propriety of the fine: While adopting the findings of dereliction of duty and gross inefficiency, the Court opted to reduce the recommended fine of P20,000.00 to P10,000.00. This reduction was made because Judge Bantugan was overtaken by the event of his compulsory retirement on March 7, 1996. The Court considered P10,000.00 as a proper amount to be withheld from his retirement benefits.
Main Doctrine
Failure to decide cases within the reglementary period constitutes dereliction of duty and gross inefficiency, warranting administrative sanctions, even if the judge is nearing compulsory retirement.