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...

Facts:

Background of the Complaint

• On September 27, 1996, Atty. Henry D. Arles filed an administrative complaint against Judge Rolindo D. Beldia of the Regional Trial Court, Bacolod City, Branch 41.
• The complaint charged the judge with gross neglect of duty, arrogance, and manifest partiality for unduly delaying the resolution of several motions in Spec. Proc. No. 94-8304 concerning the probate of the Last Will and Testament of the late Napoleon de la Rama Gonzaga.

Details of the Motions and Proceedings

• November 24, 1994 – Complainant filed a Motion directing Elsie Gonzaga to turn over to the Special Administratrix the properties of the estate under her possession.
• The motion was submitted for resolution on December 5, 1994, but remained unresolved until the complaint was filed.
• December 15, 1994 – Motion to direct Pleasantville Development Corporation to issue a sworn certification of the shares of the late Napoleon de la Rama Gonzaga in the corporation, and to place such shares under the administration of the Special Administratrix.
• Despite responsive pleadings and a subsequent motion filed on December 26, 1994, this motion too was left unresolved by respondent judge.
• February 20, 1995 – Motion to order the Special Administratrix to take charge of the estate’s properties and to set the period within which she must submit an inventory.
• The same motion was refiled on March 3, 1995 along with a manifestation on March 8, 1995, yet it remained unsettled.
• March 16, 1995 – Motion to resolve pending incidents was filed, which still awaited action at the time of the administrative complaint.
• April 22, 1996 – Motion to direct petitioner to turn over to the Special Administratrix the land titles, stock certificates, and bank deposits of the estate was filed, but no resolution was effected even after subsequent pleadings.
• July 8, 1996 – Another motion to resolve pending incidents was filed, yet the judge failed to act on it for a considerable period.

Judge’s Explanation and Counterclaims

• The respondent judge asserted that, contrary to the complainant’s allegations, a special administratrix submitted an inventory of the estate on November 14, 1994.
• He denied that the motions were left pending for more than three months.
• The judge attributed the delays to the complainant’s failure to attend scheduled hearings and his repeated filings for postponement.
• He also noted that, on several occasions, the parties indicated that negotiations for an amicable settlement were in progress.
• The pending incidents were eventually set for hearing on July 10, 1996 and resolved on October 29, 1996.

Findings from the Investigating Justice

• In a report dated November 6, 1998, Investigating Justice B. A. Adefuin-De La Cruz found that the respondent judge’s delays impeded:
• The appointment of the special administratrix, which occurred eight months after the petition was filed.
• The proper turnover and subsequent physical inventory of the estate properties.
• The report noted that, despite the special administratrix’s appointment on November 9, 1994, she was unable to prepare and submit an inventory due to the judge’s undue delays.
• The defenses presented by respondent judge were found to be misleading and untrue in light of the records.

Conclusion on the Judge’s Conduct

• Regardless of the substantive merit of the motions, the judge was expected to decide them within the 90-day reglementary period prescribed by law.
• His failure to do so constituted gross inefficiency, undermining the public’s trust in the judiciary.
• Precedents and the Rules of Court mandate prompt disposition of cases, reinforcing that undue delay violates the constitutional right to a speedy resolution.

Issue:

• Whether the respondent judge’s failure to resolve the pending motions within the prescribed 90-day period violated the constitutional right of the parties to a speedy disposition of their cases.
• Whether the prolonged and unjustified delays in rendering decisions constituted gross inefficiency and, hence, warranted administrative sanction.
• Whether the respondent judge’s justifications—such as the submission of an early inventory by the Special Administratrix and the complainant's alleged failure to attend hearings—are tenable explanations for the delays.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)