G.R. No. 161107 - Ferdo vs. St. Scholastica's College

Complainant: Pio Angelia.
Respondent: Judge Jesus L. Grageda, Regional Trial Court, Branch 4, Panabo City.
Underlying civil case: Civil Case No. 54-2001, entitled Pio Angelia v. Arnold Oghayan, originally filed on August 8, 2001.

After numerous postponements, pre-trial was finally set on December 6, 2007.
On December 6, 2007, an order was issued dismissing the case for failure to prosecute.

On December 28, 2007, after the dismissal, Angelia filed a motion for reconsideration, arguing that the failure to prosecute was not attributable to him.
On July 28, 2008, Angelia escalated the matter by filing an Urgent Motion for the Early Resolution of his Motion for Reconsideration, emphasizing the protracted delay.

On February 12, 2009, Judge Grageda provided a comment attributing the delay to:

He asserted that upon receiving the 1st Indorsement from the Office of the Court Administrator (OCA) on December 16, 2008, he acted promptly to resolve the motion.
He admitted to an apparent failure in timely resolution, citing the heavy workload of managing around 800 cases and the continuous inflow of new cases.
The challenge was further compounded by his role as the sole acting RTC judge in a district comprising two cities and three municipalities in Davao del Norte.

Judge Grageda compulsorily retired from the service on November 25, 2009.
The OCA recommended that Judge Grageda be fined P5,000.00 for the undue delay in resolving the motion.

The Constitution mandates that all lower courts decide or resolve cases or matters within three (3) months from their date of submission.

Rule 1.02, Canon 1: A judge should administer justice impartially and without delay.
Rule 3.05, Canon 3: A judge should dispose of the court’s business promptly and decide cases within the required periods.

SC Administrative Circular No. 13-87: Judges must observe the periods prescribed by Article VIII, Section 15 of the Constitution for adjudication and resolution of cases or matters.
SC Administrative Circular No. 1-88: Presiding Judges must act promptly on all motions and interlocutory matters pending before their courts.

Previous decisions have held that failure to meet prescribed periods constitutes gross inefficiency warranting administrative sanctions.
Under Section 9 and Section 11 of Rule 140 of the Revised Rules of Court, undue delay is recognized as an offense warranting penalties such as suspension or fines.

Whether the delay by Judge Grageda in resolving the December 28, 2007 Motion for Reconsideration violated the constitutional, statutory, and judicial guidelines imposing a timely disposition of cases.
Whether the explanation offered by Judge Grageda—citing workload pressures and the overwhelming number of cases—serves as a justifiable excuse for his failure to act within the required time frame.
Whether the administrative sanction of imposing a fine is an appropriate measure given the circumstances and the clear mandate for prompt judicial action.