Fajardo v. Natino
REITERATIONFacts
The Antecedents: Complainant Daniel G. Fajardo, representing Panay News, Inc., filed a complaint against Judge Antonio M. Natino, Presiding Judge of the Regional Trial Court of Iloilo City, Branch 26. The complaint alleged violations of the Constitution and the Rules of Court stemming from Judge Natino's actions in two cases: Civil Case No. 20225, a suit for annulment of title and declaration of nullity of documents, and Civil Case No. 07-29298, an action for damages and injunction. Specifically, Fajardo accused the judge of violating the 90-day period for resolving cases, delaying the release of a decision, falsifying a certificate of service, failing to act on a motion to show cause for contempt, and entertaining a second motion for reconsideration in Civil Case No. 07-29298. Fajardo theorized that these actions were maneuvers by Judge Natino to gain leverage in requesting a portion of a deposited amount. Procedural History: Following the filing of the amended complaint, the case was referred to the Executive Justice of the Court of Appeals in Cebu for investigation, report, and recommendation. The case was subsequently raffled to Investigating Justice Pamela Ann Abella Maxino. During the investigation, Judge Natino presented medical records, evidence of his duties as Acting and full-fledged Executive Judge, certifications regarding city hall renovations and power outages, approved leave applications, and a certification from the Office of the Court Administrator regarding his certificates of service. Complainant Fajardo failed to attend hearings and present evidence. Investigating Justice Maxino found no merit in most charges due to lack of evidence, except for the undue delay in resolving Civil Case No. 20225. The Investigating Justice recommended a fine of P20,000. The Office of the Court Administrator (OCA) adopted these findings and recommendations. The Petition: This Court reviewed the findings and recommendations of the Investigating Justice and the OCA. While agreeing that the allegations of intentional delay, corruption, and falsification of certificates of service were unsubstantiated by evidence, the Court concurred with the finding of guilt for undue delay in rendering the decision in Civil Case No. 20225. The Court emphasized the mandatory nature of the 90-day period for deciding cases as mandated by the Constitution and the Code of Judicial Conduct. Despite Judge Natino's explanations for the delay, including his assumption of executive duties and external factors like renovations and power outages, the Court found these insufficient to exonerate him as he did not seek an extension. Considering this was his first infraction and his retirement after 33 years of service, the Court imposed a fine of P10,000, to be deducted from his retirement benefits, as a commensurate penalty for the undue delay.
Issue(s)
Whether Judge Natino is guilty of violating the 90-day period for resolving cases and undue delay in rendering a decision. Whether Judge Natino is guilty of delaying the release of a decision. Whether Judge Natino is guilty of falsification of Certificate of Service. Whether Judge Natino failed to resolve matters covered in a Motion to Show Cause (Contempt). Whether Judge Natino is guilty of undue delay in rendering a decision.
Ruling
The Supreme Court found Judge Natino guilty of undue delay in rendering a decision in Civil Case No. 20225. He was fined ₱10,000, to be deducted from his retirement benefits. The Court found no sufficient proof for the other charges, including falsification of Certificate of Service and failure to act on the contempt motion.
Ratio Decidendi
On the charge of violating the 90-day period for resolving cases and undue delay in rendering a decision: The Court affirmed the finding of guilt against Judge Natino for undue delay in rendering the decision in Civil Case No. 20225. The records showed the case was submitted for decision on January 23, 2007, and decided only in August 2010, exceeding the mandatory 90-day period prescribed by Article VIII, Section 15(1) of the 1987 Constitution. The Court reiterated that failure to decide a case within the reglementary period is inexcusable and constitutes gross inefficiency warranting administrative sanctions. While Judge Natino presented justifications such as the resignation of his stenographer, his assumption of executive judge duties, renovation of the city hall, and power outages, these were deemed insufficient to exonerate him. The Court emphasized that judges must request extensions from the Court if they cannot decide cases promptly, as a judge cannot unilaterally extend the period. The Court noted that this was Judge Natino's first infraction and he had already retired after 33 years of service, thus finding a fine of ₱10,000 commensurate to the offense. On the charge of delay in the release of the Decision: The Investigating Justice found no proof of a pattern of delaying the release of decisions. The Court noted that the draft decision was finished on April 21, 2010, and attributed any confusion in dates to power outages. It ruled that such inadvertence did not necessarily warrant punishment but reminded judges to exercise prudence. On the charge of falsification of Certificate of Service: The Court found no clear evidence that Judge Natino intentionally falsified his certificates of service. While there was a delay in rendering the decision, it was considered an isolated case and not sufficient to conclude falsification. The questioned certificates were also not presented as evidence. On the charge of failure to resolve matters in the Motion to Show Cause (Contempt) in Civil Case No. 07-29298: The Court found the allegations unsubstantiated. Judge Natino's Order dated October 18, 2010, in the said case comprehensively refuted these charges by detailing the court's actions and the circumstances leading to postponements of hearings. On the charge of violating the 90-day period for resolving cases and undue delay in rendering a decision: The Court affirmed the finding of guilt against Judge Natino for undue delay in rendering the decision in Civil Case No. 20225. The records showed the case was submitted for decision on January 23, 2007, and decided only in August 2010, exceeding the mandatory 90-day period prescribed by Article VIII, Section 15(1) of the 1987 Constitution. The Court reiterated that failure to decide a case within the reglementary period is inexcusable and constitutes gross inefficiency warranting administrative sanctions. While Judge Natino presented justifications such as the resignation of his stenographer, his assumption of executive judge duties, renovation of the city hall, and power outages, these were deemed insufficient to exonerate him. The Court emphasized that judges must request extensions from the Court if they cannot decide cases promptly, as a judge cannot unilaterally extend the period. The Court noted that this was Judge Natino's first infraction and he had already retired after 33 years of service, thus finding a fine of ₱10,000 commensurate to the offense.
Main Doctrine
Failure to decide a case within the reglementary period is inexcusable and constitutes gross inefficiency warranting administrative sanctions. While justifications for delay may be considered, they are not sufficient to exonerate a judge from liability if the mandatory period is not observed and no extension was sought.