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(DIGEST) (180) Office of The Court Administrator v. Espanol October 18 2004 A.M. No. RTJ-04-1872
(DIGEST) (180) Office of The Court Administrator v. Espanol October 18 2004 A.M. No. RTJ-04-1872
FACTS:
Prior to the compulsory retirement of Judge Dolores L. Español, or the respondent herein, the
Office of the Court Administrator (OCA) directed her to decide cases submitted for decision,
resolve all motions/incidents submitted for resolution and to take actions on the unacted cases
as tabulated in the memorandum. OCA found that respondent left a total of 69 cases that had
not been acted upon.
Respondent judge explained that the delay was due to “human limitations”, as she was only
able to receive the memorandum from OCA, two (2) days before her retirement. She argues
that she had to give priority to Election Protest, as required by the law. She alleged that she
approached the Court Management Officer (CMO) and discussed the possibility of requesting
another judge to assist her. On the advice of the CMO, however, she did not submit a formal
request.
OCA found respondent guilty of gross inefficiency and recommended a fine of ten thousand
pesos (PHP 10,000) to be deducted from the retirement benefits
ISSUE:
Whether or not the Respondent is guilty of gross inefficiency
FACTS:
The Supreme Court ruled in the affirmative.
The 1987 Constitution mandates trial judges to dispose of the court’s business promptly and to
decide cases and matters within three (3) months from the filing of the last pleading, brief or
memorandum. In the disposition of cases, members of the bench have always been exhorted to
observe strict adherence to the foregoing rule to prevent delay, a major culprit in the erosion of
public faith and confidence in our justice system.
Clear failure to comply with the reglementary period is regarded as inexcusable gross
inefficiency.
The speedy disposition of cases by judges is unequivocally directed by Canon 6 of the Code of
Judicial Ethics: "He should be prompt in disposing of all matters submitted to him,
remembering that justice delayed is often justice denied.”
This Court has, in several instances, advised judges to follow certain guidelines to facilitate
speedy case disposition. Among these measures is the discouragement of continuances, except
for exceptional reasons. The magistrates do not only hear cases and write decisions in the
seclusion of their chambers; equally important, they act also as administrators. They should be
rational and realistic in calendaring cases; unless the docket of the court requires otherwise,
not more than four cases daily should be scheduled for trial. A continuous and physical
inventory of cases on a monthly basis is also recommended, so that they would be aware of the
status of each case.
While decision-writing is a matter of personal style, judges are well-advised to prepare concise
but complete as well as correct and clear decisions, orders or resolutions. At times,
circumstances beyond their control result in the accumulation of ripe cases to a daunting
number, making it humanly impossible for them to comply with the constitutionally mandated
90-day period. In such instances, all that they should do is write a request for extension from
the Supreme Court, stating therein their reasons for the delay. Such administrative requirement
finds basis in the 1987 Constitution. This Court has further directed members of the bench to
call the attention of the OCA "when the situation requires remedies beyond the control or
capability of the judges."
We close this Decision with a final exhortation. The magistracy is a very exacting and
demanding vocation. Judges are expected to embody "four-character traits: integrity,
independence, intelligence and industry." Moreover, in the performance of their tasks, they
must exhibit "four work habits; namely, excellence, ethics, effectiveness and expeditiousness."
Only those who patiently cultivate these four-character traits and four work habits can succeed
in journeying through the straight and narrow judicial path.
WHEREFORE, the factual findings of the Office of Court Administrator are ADOPTED. Judge
Dolores L. Español is found GUILTY of gross inefficiency and is fined in the amount of eleven
thousand pesos (₱11,000), to be deducted from the retirement benefits due her.