G.R. No. 172902 - Seneres vs. Sabido IX

Engr. Fundador Ambalong, the complainant, is the plaintiff in Civil Case No. 311 entitled "Ambalong vs. Jose Castillon and Rudy Castillona" filed for damages based on quasi-delict.
The case was pending before the Metropolitan Circuit Trial Court, Siquijor-Enrique Villanueva-Larena, under the supervision of Judge Antonio C. Lubguban, the respondent.

After the termination of the proceedings on September 13, 1999, the respondent directed the parties to file their respective memoranda within 30 days from the receipt of the last transcript.
The complainant filed his memorandum on January 5, 2000, whereas the defendants failed to submit any memorandum.

Despite the filing of the last pleading on January 5, 2000, no decision was rendered in Civil Case No. 311 until November 27, 2000.
The respondent judge admitted that he had drafted the decision for both the civil case and a related criminal case, which arose from the context of the same litigation, yet kept the draft in his office cabinet for further editing, resulting in the delay.

Complainant alleged that the decision in the civil case was not rendered within the constitutionally mandated three-month period starting from the last pleading.
Additionally, it was highlighted that while the decision for a separate criminal case was issued on February 21, 2001 (acquitting one of the defendants), the civil case decision remained unserved until the office clerk mailed copies on March 6, 2001.

The respondent acknowledged that the decision was ready before the expiration of the three-month period; however, he delayed releasing it due to his intent to conduct final editing.
He attributed the delay partly to a crowded docket and his simultaneous responsibility over another court sala at MCTC-Lazi, Siquijor.
The respondent denied intentional delay or any malice, bias, or gross neglect in managing the civil case.

Evaluation and Recommendation by the Office of the Court Administrator (OCA)

OCA found the respondent judge guilty of gross inefficiency for failing to decide the case within the prescribed three-month period.
The evaluation underscored that a judge’s crowded docket and concurrent assignments do not exempt him from the constitutional duty to render decisions in a timely manner.
OCA recommended that the case be redocketed as a regular administrative case, and that the respondent judge be fined P5,000.00.
The report emphasized that had the judge anticipated delays, he should have sought an extension of time, which he did not.

Whether the respondent judge’s delay in rendering the decision on Civil Case No. 311 constitutes a violation of the constitutional mandate requiring that lower court cases be decided within three months from the filing of the last pleading.

Determination of the timeliness of the decision submission given that the last pleading was filed on January 5, 2000.
Whether the judge’s explanation involving a crowded docket and simultaneous management of another sala is a sufficient justification for the delay.

Whether the delay in serving the decision on the parties further compounded the respondent judge’s alleged gross inefficiency.

Examination of the procedural lapse when copies of the decision were not served on time.
Impact of the administrative oversight on the delivery of justice.

Whether administrative sanction in the form of a fine of P5,000.00 is appropriate and supported by the evidence and judicial standards.

Consideration of judicial rules and guidelines on prompt administration of justice.
Evaluation of previous cases and the principle that “justice delayed is justice denied.”