RTC, Branch 55 vs. Audit and Inventory of Cases

A.M. No. 96-3-88-RTC (September 30, 1996)

Judge Bantugan fined ₱10,000 for delaying cases, breaching ethics and public trust.

Facts:

This administrative matter originated from a directive issued by Deputy Court Administrator Reynaldo L. Suarez on February 22, 1996, which instructed a team to conduct an audit and physical inventory of the records of cases pending in the Regional Trial Court, Branch 55, Alaminos, Pangasinan. This branch was presided over by Judge Vivencio A. Bantugan, who was approaching his compulsory retirement on March 7, 1996.

As of December 31, 1995, it was reported that Branch 55 had a total caseload of 324 cases, which included 16 criminal cases with detention prisoners, 171 criminal cases without detention prisoners, 114 ordinary civil cases, and 23 other cases. Notably, there were 21 civil cases and 1 criminal case that had been pending without any action for an extended period.

Following the audit, a report dated May 20, 1996, revealed several concerning findings: Judge Bantugan had not taken any action on 1 criminal and 21 civil cases pending in his sala; 2 civil cases had been submitted for decision beyond the 90-day reglementary period; and there were 7 inherited civil cases and 14 inherited criminal cases that had also remained undecided despite being submitted for decision.

In light of these findings, the Deputy Court Administrator recommended that Judge Bantugan be fined P20,000 for his dereliction of duty, which included non-action on 22 cases and delays in deciding cases submitted for decision beyond the mandated period.

Legal Issues:

The primary legal issues involved in this case were:

  1. Whether Judge Bantugan's failure to act on the pending cases constituted a dereliction of duty and gross inefficiency.
  2. The appropriateness of the recommended administrative sanction (fine) against Judge Bantugan in light of his impending retirement.

Arguments:

The arguments presented by both sides can be summarized as follows:

  • For the Administrative Complaint: The Deputy Court Administrator's report highlighted Judge Bantugan's failure to comply with Canon 3, Rule 3.05 of the Code of Judicial Conduct, which requires judges to dispose of court business promptly and within the required periods. The report emphasized that the delays in deciding cases eroded public confidence in the judiciary and constituted serious misconduct detrimental to the integrity of the judicial office.

  • For Judge Bantugan: Judge Bantugan contended that he had exerted efforts to decide the inherited cases but was unable to do so due to his impending retirement. However, he failed to provide any substantial justification for the delays in deciding the cases within the required timeframes.

Court's Decision and Legal Reasoning:

The court adopted the findings of the Deputy Court Administrator and concluded that Judge Bantugan's failure to act on the pending cases and to decide cases submitted for decision within the prescribed 90-day period amounted to gross inefficiency and serious misconduct. The court underscored the importance of timely case resolution as mandated by Section 15 (1) (2), Article VIII of the Constitution, which aims to prevent delays in the administration of justice.

The court acknowledged Judge Bantugan's impending retirement but determined that this did not excuse his failure to decide cases within the required period. Consequently, the court decided to reduce the recommended fine from P20,000 to P10,000, which would be deducted from his retirement benefits.

Significant Legal Principles or Doctrines Established:

  1. Judicial Efficiency: The case reinforces the principle that judges are required to dispose of cases promptly and within the timeframes established by law to uphold the integrity of the judiciary and maintain public confidence.
  2. Administrative Accountability: The ruling illustrates that judges can be held administratively accountable for delays in case resolution, and such delays can lead to sanctions even in light of retirement.
  3. Regulatory Compliance: The decision emphasizes the necessity for judges to comply with the Code of Judicial Conduct and constitutional mandates regarding the timely resolution of cases.