Angelia v. Grageda

A.M. No. RTJ-10-2220 (February 7, 2011)

Facts:

The case involves a verified complaint filed by Pio Angelia against Judge Jesus L. Grageda of the Regional Trial Court, Branch 4, Panabo City, for delay in resolving motions related to Civil Case No. 54-2001, which was initiated on August 8, 2001. After several postponements, a pre-trial was finally scheduled for December 6, 2007. However, on December 20, 2007, Angelia's counsel received an order dismissing the case for failure to prosecute. In response, Angelia filed a motion for reconsideration on December 28, 2007, arguing that the failure to prosecute was not attributable to him.

Despite the filing of an Urgent Motion for the Early Resolution of the motion for reconsideration on July 28, 2008, no action was taken by Judge Grageda for an extended period. In his comment dated February 12, 2009, Judge Grageda attributed the delay to numerous resettings and the repeated absences of the parties involved. He claimed that upon receiving an indorsement from the Office of the Court Administrator (OCA) on December 16, 2008, he promptly resolved the motion for reconsideration. Judge Grageda acknowledged the delay but argued it was not intentional, citing the heavy workload of approximately 800 cases in his sala and the fact that he was often the only acting RTC judge in his district.

Judge Grageda retired from service on November 25, 2009, and the OCA recommended a fine of P5,000.00 for the delay.

Legal Issues:

1. Whether Judge Grageda's delay in resolving the motion for reconsideration constituted a violation of the Code of Judicial Conduct and warranted administrative sanctions.
2. The appropriateness of the recommended penalty by the OCA in light of the circumstances surrounding the case.

Arguments:

• Complainant's Argument (Angelia): Angelia contended that the delay in resolving his motion for reconsideration was unjustified and detrimental to his right to a speedy resolution of his case. He emphasized that the delay was excessive and violated the rules governing the prompt disposition of cases.

• Respondent's Argument (Judge Grageda): Judge Grageda admitted to the delay but argued that it was due to the overwhelming number of cases he was handling and was not intentional. He expressed remorse for the delay and promised to improve his performance in the future.

Court's Decision and Legal Reasoning:

The Court found Judge Grageda guilty of undue delay in resolving the motion for reconsideration, which violated Rule 1.02 of Canon 1 and Rule 3.05 of Canon 3 of the Code of Judicial Conduct. The Court emphasized the constitutional mandate that all lower courts must decide cases within three months from submission and reiterated that judges are required to act promptly on motions and other matters pending before them.

The Court rejected Judge Grageda's explanation regarding the volume of work as a valid excuse for the delay. It noted that he should have filed a request for an extension if he was unable to resolve the motion within the prescribed period. The Court underscored that delays in the administration of justice undermine public confidence in the judiciary and that "justice delayed is justice denied."

In determining the appropriate penalty, the Court considered the recommendation of the OCA and the circumstances of the case. It concluded that a fine of P5,000.00 was appropriate given the context of the judge's workload and the nature of the offense.

Significant Legal Principles or Doctrines Established:

1. Judges are mandated to resolve cases and motions promptly, adhering to the timelines set forth in the Constitution and the Code of Judicial Conduct.
2. Delays in the resolution of cases are not excusable and can lead to administrative sanctions against judges, reinforcing the principle that justice must be administered without undue delay.
3. The Court has the authority to impose fines as a penalty for administrative offenses, taking into account the specific circumstances surrounding each case.