Batingana, Re: Request of
REITERATIONFacts
The Antecedents: Judge Nino A. Batingana, Presiding Judge of Branch 6, Regional Trial Court, Mati City, Davao Oriental, requested extensions of time to decide Civil Case No. 2049, entitled "Nenita A. Villa v. Julius Jupia, et al." for specific performance and damages. Procedural History: The Supreme Court, by Resolution of March 30, 2009, denied Judge Batingana's fourth and fifth requests for extension totaling 180 days, noting that the requests for the first, second, and third extensions were not received and that the due date had already elapsed. He was directed to immediately furnish a copy of the decision upon rendition. The Petition: A copy of Judge Batingana's Decision dated October 16, 2009, was received by the Office of the Court Administrator (OCA) on November 11, 2009. The OCA found that the case was due for resolution on September 5, 2008, meaning the judge incurred a delay of over one year. The OCA recommended a fine of P10,000. The Court found that even with granted extensions, the decision was rendered more than seven months late.
Issue(s)
Whether Judge Nino A. Batingana committed undue delay in rendering a decision in Civil Case No. 2049. Whether the penalty recommended by the OCA is appropriate given the circumstances, including prior offenses.
Ruling
The Supreme Court found Judge Nino A. Batingana guilty of undue delay in rendering a decision in Civil Case No. 2049. Consequently, he was FINED in the amount of Twenty Five Thousand (P25,000.00) Pesos with a stern warning that any further commission of the same or similar act shall be dealt with most severely.
Ratio Decidendi
On Whether Judge Nino A. Batingana committed undue delay in rendering a decision in Civil Case No. 2049: The Court affirmed that Judge Batingana committed undue delay. The case was due for resolution on September 5, 2008, as stated in his own letter. Even if his requests for extensions totaling 180 days were granted, the decision would have been due by March 4, 2009. However, he rendered the decision only on October 16, 2009, which is more than seven months beyond the extended deadline. This delay significantly exceeds the constitutional mandate of 90 days for lower courts to decide cases. The Court emphasized that any delay in the administration of justice undermines public faith in the judiciary and reinforces the perception that justice is slow. On Whether the penalty recommended by the OCA is appropriate given the circumstances, including prior offenses: The Court increased the penalty recommended by the OCA. It noted that this was Judge Batingana's third offense of the same nature. He had previously been fined P11,000 in A.M. No. 08-2-107-RTC and P20,000 in A.M. No. 05-8-463-RTC, with warnings that repetition would be dealt with more severely. Considering these prior offenses and warnings, the Court imposed a fine of P25,000, which is higher than the OCA's recommendation, and issued a stern warning that a future infraction would be met with more severe consequences. The Court reiterated that undue delay is a less serious charge under Rule 140 of the Rules of Court, and while penalties are prescribed, the Court has discretion to impose fines within or even outside the prescribed range, especially in cases of repeated offenses.
Main Doctrine
Judges are constitutionally and statutorily bound to decide cases within the prescribed 90-day period. Failure to do so constitutes undue delay, a less serious charge under Rule 140 of the Rules of Court. Repeated instances of such delay are subject to progressively severe penalties, including substantial fines and stern warnings against future infractions, underscoring the judiciary's commitment to efficient and prompt administration of justice.