All cases or matters filed after the effectivity of this Constitution must be decided or resolved within twenty-four months from date of submission for the Supreme Court, and, unless reduced by the Supreme Court, twelve months for all lower collegiate courts, and three months for all other lower courts. [Sec. 15 (1), Art. VIII, 1987 Constitution]

Facts: 

Maquiran filed a suit for damages arising from the death of her husband due to an accident docketed as Civil Case No. 7548. The case was assigned to Judge Lopez. The case was submitted for decision in August 1994. However, up to the time the complaint in this case was filed on September 16, 1999, no decision had as yet been rendered by respondent judge.

Thus, Maquiran filed an administrative complaint for gross negligence against Judge Lopez. In her comment, respondent judge claimed that she had finally decided the case and given copies of the decision to the parties. She explained that during the almost five years that the case was pending decision, many things had happened to her: that she was confined in the hospital and was scheduled for an operation for the removal of a mass in her uterus, but for her extremely high blood pressure; that her parents died and she was left with the responsibility of having to take care of her retardate sister and a brother who was suffering from a nervous breakdown; that as Executive Judge, she was given additional administrative duties; and that she had to conduct continuous hearings by reason of the designation of her court as a Special Criminal Court.

The Office of the Court Administrator found respondent administratively liable and recommended that she be ordered to pay a fine of P4,000.00 for inefficiency with a stern warning that a repetition of the same or similar act shall be dealt with more severely.


Issue:

Whether or not respondent judge is guilty of gross negligence


Held:

Yes. Under Art. VIII, 15(1) of the Constitution, lower courts have three months within which to decide cases or resolve matters submitted to them for resolution. Canon 3, Rule 3.05 of the Code of Judicial Conduct enjoins judges to dispose of their business promptly and decide cases within the required period. Indeed, this Court has constantly impressed upon judges may it not be said without success the need to decide cases promptly and expeditiously, for it cannot be gainsaid that justice delayed is justice denied. For delay in the disposition of cases undermines the peoples faith and confidence in the judiciary. Hence, failure of judges to render judgment within the required period constitutes gross inefficiency warranting the imposition of administrative sanctions on them.

The reasons adduced by respondent judge for her failure to decide Civil Case No. 7548 for a period of five years is unsatisfactory. While respondent judge claimed that she had decided the case and had in fact furnished the parties copies of the same, she did not state when she had done so. It would appear that she did so only shortly before she filed her comment on the complaint in this case on January 10, 2000, after a delay of more than five years. Hence, her excuse. Although we are inclined to be compassionate, respondent must realize that compassion has its limits. After all, respondent could have asked for time within which to decide cases, although not for such a long time as five years. Then, too, she could have gone on sick leave. But for her not to decide a case for five years cannot be wholly excused. A heavy caseload may excuse a judges failure to decide cases within the reglementary period, but not her failure to request an extension of time within which to decide the case on time.

Respondent likewise blames her failure to decide Civil Case No. 7548 on her administrative duties as Executive Judge of the Regional Trial Court of Pasay City and the fact that she was required to conduct continuous trials because her court had been designated a Special Criminal Court. However, she could have declined her designation as Executive Judge. She could also have asked to be relieved of her other duties. But she never did so. Judge was fined P5,000 with warning. (Maquiran vs. Judge Lopez, A.M. No. RTJ-00-1606, June 20, 2001)