Philippine Supreme Court Jurisprudence

From September 19, 2016 to October 1, 2016, a judicial audit was conducted in Branches 61 and 62, Regional Trial Court (RTC), Gumaca, Quezon, and all the Municipal Trial Courts (MTC)/Municipal Circuit Trial Courts (MCTC) under the said RTC's jurisdiction. The results thereof,¹ particularly with respect to the MTC, Pitogo, Quezon presided by Judge Walter Inocencio V. Arreza (Judge Arreza), showed, that out of the 35 pending cases, there were numerous undecided cases which had been overdue for several years.²

In view of this, Deputy Court Administrator Raul B. Villanueva (DCA Villanueva) issued a Memorandum³ dated October 28, 2016 to Judge Arreza which stated in part, viz.:

x x x x

MTC Pitogo, Quezon, has six (6) court personnel headed by the Clerk of Court II, Ms. Mederlyn F. Orfanel. We note that the positions of Court Stenographer I and Clerk II are vacant. The court's latest monthly reports of cases for the last six (6) months show the clearance and disposition rates and average inflow and outflow of cases as follows:

�	Pending Beginning	Inflow	Outflow	Pending Cases	Clearance Rate (Outflow�Inflow)	Disposition Rate [Outflow�(Beg+Inflow)]
Mar-16	45	1	4	42	183.33%	21.57%
Apr-16	42	0	1	41
May-16	41	0	2	39
Jun-16	39	4	2	41
Jul-16	41	0	0	41
Aug-16	41	1	2	40
Average	�	1	2

While the clearance rate may appear high at 183.33%, the disposition rate is quite low at 21.57%. The data also shows that the high clearance rate is only due to the fact that very few cases are being filed in court, or an average of 1 case per month. The disposal of the court leaves much to be desired. It was able to dispose of only 2 cases per month, on the average.

The audit team examined a total of 35 pending cases (cutoff is 31 August 2016). Of these cases, 23 were already submitted for decision; all are already overdue for several months and even years, with the exception of 1 case. Thus, if we remove the 23 cases submitted for decision from the 35 pending cases, [Judge Arreza was] left with only 12 cases in active trial. With only 12 cases to handle, Judge Arreza clearly had more than enough time to render decisions. Further, we see no reason why there could still be any protracted proceedings. But surprisingly, there were 7 cases that have been pending trial for over 3 years. In fact, the oldest case has been pending trial for almost 9 years x x x.

In view of the above observations, Judge Arreza should be made to explain why no administrative sanction should be imposed against him for gross inefficiency and undue delay in deciding cases.⁴

Thus, Judge Arreza was ordered to:

x x x x

1. IMMEDIATELY DECIDE the [twenty-three (23), cases submitted for decision x x x which are overdue;
   
   
2. TAKE APPROPRIATE ACTION on the one (1) case with no further action/setting for a considerable length of time x x x;^5]
   
   
3. EXPEDITE the disposition of the seven (7) cases aged three (3) years and above and SUBMIT a status report thereon as of 30 June 2017 on or before 5 July 2017;⁶ and
   
   
4. SUBMIT copies of the pertinent decisions and orders, as proof of the action taken on Item Nos. 1(a) and 1(b) above, on or before 30 December 2016, together with a written explanation why no administrative sanction should be imposed against [Judge Arreza for] gross inefficiency and undue delay in deciding cases.

x x x x

For strict compliance.⁷

In the Compliance⁸ dated December 27, 2016, a table was presented indicating that: (1) all of the 23 cases submitted for decision had already been resolved/decided; (2) the one case with no further action/setting for a considerable length of time had already been acted upon;⁹ and (3) two of the seven pending cases aged three years and above had already been resolved while the remaining five were undergoing hearings. Judge Arreza likewise submitted his written explanation¹⁰ dated December 29, 2016 wherein he admitted his inefficiency. He, however, begged for understanding and narrated the circumstances which he claimed led to his failure to act on and decide cases. According to him, he and his wife were having marital problems in 2008 or just a year after his appointment as Judge. Things became worse in March 2010 when his wife finally left him and their children. In December 2012, he suffered a stroke, was hospitalized for two weeks, and almost became paralyzed. He has since then started taking maintenance medicine and was lucky enough to have now recovered. All these, according to Judge Arreza, took a toll in his performance as a judge. Be that as it may, he now undertakes to perform all his tasks, duties and responsibilities in line with the Court's mission and vision.

In the latest update¹¹ dated July 3, 2017, Judge Arreza reported the status/specific actions taken on the remaining five cases aged over three years and beyond which as of the said date were still in active trial.

Recommendation of the Office of the Court Administrator (OCA)

In its Memorandum¹² of July 20, 2017, the OCA made the following observations:

Judge Arreza's explanation that he experienced marital problems and suffered a stroke in 2012 cannot justify the delay. While we commiserate with him for having been abandoned by his wife and having to take care of their children on his own, such is not a valid ground to excuse his failure to discharge his duties. We note that his stroke happened years ago in 2012. How he allowed his court to incur the 23 overdue cases for too long a time despite only around 12 active cases to hear at a once a month hearing schedule, is abhorrent. More than half of said cases were in fact submitted for decision even prior to his stroke. We note further that after said cases were discovered during the audit, he was able to dispose of all of them within a three (3) month period without a hitch. This only shows that he had the capability but chose not to act on said cases.

This Court has consistently impressed upon the members of the Bench the need to decide cases promptly and expeditiously, on the time-honored principle that justice delayed is justice denied.

As frontline officials of the Judiciary, trial court judges should at all times act with dedication, efficiency, and a high sense of duty and responsibility as the delay in the disposition of cases is a major culprit in the erosion of public faith and confidence in the judicial system.

This is embodied in Rule 3.05, Canon 3 of the Code of Judicial Conduct which states that a judge shall dispose of the court's business promptly and decide cases within the required periods; and in Section 5, Canon 6 of the New Code of Judicial Conduct for the Philippine Judiciary which provides that judges shall perform all judicial duties, including the delivery of reserved decisions, efficiently, fairly, and with reasonable promptness.

No less that the Constitution requires that cases at the trial court level be resolved within three (3) months from the date they are submitted for decision, that is, upon the filing of the last pleading, brief, or memorandum required by the Rules of Court or by the court itself. This three (3)-month or ninety (90)-day period is mandatory and failure to comply can subject the judge to disciplinary action.¹³ Accordingly, the OCA recommended that Judge Arreza be held liable for gross inefficiency and undue delay in deciding cases and fined in the amount of P40,000.00, with stern warning, it being his first offense.

The Court's Ruling

The Court adopts the findings of the OCA with modification as regards the recommended penalty.

The Court's policy on prompt resolution of disputes cannot be overemphasized.¹⁴ In Guerrero v. Judge Deray,¹⁵ it stated:

As has been often said, delay in the disposition of cases undermines the people's faith in the judiciary. Hence, judges are enjoined to decide cases with dispatch. Their failure to do so constitutes gross inefficiency and warrants the imposition of administrative sanctions on them. Appellate magistrates and judges alike, being paradigms of justice, have been exhorted time and again to dispose of the court's business promptly and to decide cases within the required periods. Delay not only results in undermining the people's faith in the judiciary from whom the prompt hearing of their supplications is anticipated and expected; it also reinforces in the mind of the litigants the impression that the wheels of justice grind ever so slowly.

Here, Judge Arreza himself admitted his inefficiency. While he attributed this to domestic and health issues, suffice it to say that said reasons, even if found acceptable, cannot excuse him but, at most, can only mitigate his liability. Unfortunately for him, the Court shares the OCA's observation that the problems alluded to by Judge Arreza happened years before the judicial audit was conducted in 2016. If he was really inclined to dispose of the backlog caused by his domestic and health problems, he should have immediately done so. Note that his separation from his wife happened way back in 2010 and his stroke in 2012. To the mind of the Court, Judge Arreza had more than enough time to catch up before the conduct of the judicial audit in 2016 especially considering that his sala has a manageable case load due to the low average of case inflow which was only one case a month. Moreover, the Court notes that, with respect to the cases already submitted for decision but not decided within the prescribed period, Judge Arreza failed to ask for extension to decide the same. It has been previously held that "[i]n case of poor health, the Judge concerned needs only to ask this Court for an extension of time to decide cases, as soon as it becomes clear to him that there would be delay in the disposition of his cases."¹⁶ To stress, Judge Arreza never bothered to ask the Court for an extension after he suffered a stroke. In fact, even before his stroke, there were already cases which were overdue for decision for which no motions for extension were made. Anent the cases with protracted proceedings, the Court shares the observation of the OCA that there was no reason for them to undergo a long-drawn-out trial considering that there were only 12 cases supposedly in active trial.

Given the foregoing, it is not difficult to see that the delay in Judge Arreza's disposition of cases was the product of his apathy. This becomes even more apparent in light of the fact that Judge Arreza was able to dispose of all the 23 cases overdue for decision within three (3) months and act on the other cases after his attention was called by the OCA. Indeed, and as correctly observed by the OCA, Judge Arreza has the capability but simply chose not to act on the subject cases.¹⁷

Again, it bears to stress that "[a] judge's foremost consideration is the administration of justice."¹⁸ Judges must "decide cases promptly and expeditiously under the time-honored precept that justice delayed is justice denied. Every judge should decide cases with dispatch and should be careful, punctual, and observant in the performance of his functions for delay in the disposition of cases erodes the faith and confidence of our people in the judiciary, lowers its standards and brings it into disrepute."¹⁹

As "delay in the disposition of cases is tantamount to gross inefficiency on the part of a judge",²⁰ the OCA correctly found Judge Arreza guilty of gross inefficiency for his undue delay in rendering decisions and failure to act on cases with dispatch. Under Section 11, Rule 140 of the Rules of Court, the same is punishable by (1) suspension from office without salary and other benefits for not less than one (1) nor more than three (3) months; or (2) a fine of more than P10,000.00 but not exceeding P20,000.00. Considering that this is Judge Arreza's first offense, the imposition of fine in the amount of P15,000.00 is in order.

WHEREFORE, Judge Walter Inocencio V. Arreza is hereby found GUILTY of Gross Inefficiency for his undue delay in rendering decisions and failure to act on cases with dispatch. He is ordered to pay a FINE of P15,000.00 and STERNLY WARNED that a repetition of the same or similar act or omission will be dealt with more severely.

SO ORDERED.

Leonardo-De Castro,^*Jardeleza, and Tijam, JJ., concur.
Sereno, C.J., on leave.

Endnotes:

^* Acting Chairperson per Special Order No. 2540 dated February 28, 2018.

¹ See Judicial Audit Report dated October 28, 2016, rollo, pp.53-56.

² Id. at 55.

³ Id. at 47-52.

⁴ Id. at 47-48.

⁵ Said case apparently forms part of the 12 cases supposedly in active trial.

⁶ Said cases apparently form part of the 12 cases supposedly in active trial.

⁷Rollo, pp. 51 -52.

⁸ Id. at 42-46.

⁹ An Order was issued causing the case to be archived. At the same time, an alias warrant for the arrest of the accused in the said case was issued.

¹⁰Rollo, pp. 40-41.

¹¹ Id. at 1-3.

¹² Id. at 57-61.

¹³ Id. at 60-61.

¹⁴Re: Report on the Judicial Audit Conducted in the Regional Trial Court - Branch 56, Mandaue City, 658 Phil. 533, 540 (2011).

¹⁵ 442 Phil. 85, 92-93 (2002).

¹⁶Balajedeong v. Judge Del Rosario, 551 Phil. 458, 467 (2007).

¹⁷Rollo, p. 60.

¹⁸Salvador v. Judge Limsiaco, Jr., 574 Phil. 521, 524 (2008).

¹⁹Re: Findings on the Judicial Audit Conducted in Regional Trial Court, Branch 8, La Trinidad, Benguet, A.M. No. 14-10-339-RTC, March 7, 2017.

²⁰Arap v. Judge Mustafa, 428 Phil. 778, 782 (2002).