Case Digest (A.M. No. RTJ-05-1964)
Facts:
On September 27, 1996, Atty. Henry D. Arles filed an administrative complaint against Judge Rolindo D. Beldia, who presided over the Regional Trial Court, Branch 41, in Bacolod City, Negros Occidental. The complaint alleged gross neglect of duty, arrogance, and manifest partiality due to the judge's failure to resolve several motions related to Special Proceedings No. 94-8304, which concerned the petition to approve the last will and testament of the late Napoleon de la Rama Gonzaga. Atty. Arles represented Ma. Ana Julie Gonzaga, one of the heir-oppositors in the case. The complainant detailed a series of motions he filed starting from November 24, 1994, which included requests for the turnover of estate properties and the appointment of a special administratrix. Despite the motions being submitted for resolution, they remained unresolved for an extended period, with the last motion filed on April 22, 1996, and the complaint lodged in September 1996. In response, Judge Be...
Case Digest (A.M. No. RTJ-05-1964)
Facts:
Background of the Case
- On September 27, 1996, Atty. Henry D. Arles filed an administrative complaint against Judge Rolindo D. Beldia of the Regional Trial Court (RTC) of Bacolod City, Branch 41, for gross neglect of duty, arrogance, and manifest partiality.
- The complaint arose from the undue delay in resolving several motions filed in Special Proceedings No. 94-8304, a case involving the probate of the last will and testament of the late Napoleon de la Rama Gonzaga.
- Complainant Atty. Arles represented Ma. Ana Julie Gonzaga, one of the heir-oppositors in the case.
Specific Allegations of Delay
Motion to Direct Elsie Gonzaga to Turn Over Properties (November 24, 1994)
- Filed on November 24, 1994, and submitted for resolution on December 5, 1994.
- Remained unresolved as of September 27, 1996, when the complaint was filed.
Motion to Direct Pleasantville Development Corporation to Issue Certification (December 15, 1994)
- Filed on December 15, 1994, with the last responsive pleading filed on December 26, 1994.
- Despite subsequent motions to resolve, it remained unresolved as of the filing of the complaint.
Motion to Order Special Administratrix to Take Charge of Properties (February 20, 1995)
- Filed on February 20, 1995, with a follow-up motion on March 3, 1995, and a manifestation on March 8, 1995.
- Remained unresolved as of the filing of the complaint.
Motion to Resolve Pending Incidents (March 16, 1995)
- Filed on March 16, 1995, but no action was taken as of the filing of the complaint.
Motion to Direct Petitioner to Turn Over Land Titles, Stock Certificates, and Bank Deposits (April 22, 1996)
- Filed on April 22, 1996, but remained unresolved as of the filing of the complaint.
Motion to Resolve Pending Incidents (July 8, 1996)
- Filed on July 8, 1996, but no action was taken as of the filing of the complaint.
Respondent Judge’s Defense
- Respondent Judge Beldia claimed that the special administratrix had submitted an inventory of the estate as early as November 14, 1994.
- He denied that the motions remained unresolved for more than three months, attributing any delay to the complainant’s failure to attend scheduled hearings and the parties’ ongoing negotiations for settlement.
- He argued that all pending incidents were resolved on October 29, 1996, after being set for hearing on July 10, 1996.
Findings of the Investigating Justice
- The investigating justice found that Judge Beldia’s delay in resolving the motions caused significant delays in the probate proceedings, including the appointment of the special administrator and the turnover of estate properties.
- It was noted that the judge favored petitioner Elsie Gonzaga Salgado by tolerating delays in the inventory of estate properties.
- The investigating justice recommended a six-month suspension without pay for Judge Beldia.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Duty to Resolve Motions Promptly
- Judges are mandated by the Constitution and the Code of Judicial Conduct to dispose of court business promptly and decide cases within the required periods.
- Rule 3.05 of the Code of Judicial Conduct requires judges to resolve motions within 90 days from the filing of the last pleading.
Consequences of Delay
- Unreasonable delay in resolving motions erodes public confidence in the judiciary and violates the parties’ constitutional right to a speedy disposition of their cases.
- Delay in probate proceedings, as in this case, prejudices the heirs and other parties involved.
Gross Inefficiency
- Judge Beldia’s failure to resolve the motions within the prescribed period constitutes gross inefficiency, warranting administrative sanction.
- The Court cited precedents, such as Gonzales v. Judge Hidalgo, where similar delays were deemed gross inefficiency.
Appropriate Penalty
- Under Section 9, Rule 140 of the Rules of Court, undue delay in rendering a decision or order is a less serious offense punishable by suspension or a fine.
- Given the circumstances, including Judge Beldia’s prior disciplinary record, the Court deemed a fine of P20,000.00 appropriate.
Rationale for the 90-Day Reglementary Period
- The 90-day period is designed to ensure prompt resolution of cases and motions, reinforcing public trust in the judiciary.
- Delay undermines the judiciary’s role as a dispenser of justice and reinforces the perception that justice is slow.
Conclusion:
- The Supreme Court emphasized the importance of prompt resolution of cases and motions to maintain public trust in the judiciary.
- Judge Beldia’s failure to comply with this duty resulted in a fine of P20,000.00 and a stern warning against future delays.