Case Digest (A.M. No. MTJ-11-1793)
Facts:
This case involves an administrative complaint filed by Antonio Y. Cabasares (complainant) against Judge Filemon A. Tandinco, Jr. (respondent) of the Municipal Trial Court in Cities, 8th Judicial Region, located in Calbayog City, Western Samar. The complaint was lodged on November 6, 2009, alleging undue delay in rendering a decision in Criminal Case No. 8864, which was a Complaint for Malicious Mischief against Rodolfo Hebaya. The case was submitted for decision as early as February 27, 2002, but by the time the complaint was filed, the respondent had not yet issued a ruling. This delay was deemed a violation of Section 15 (1), Article VIII of the 1987 Philippine Constitution and Canon 3, Rule 3.05 of the Code of Judicial Conduct. In his defense, Judge Tandinco claimed he only became aware of the complaint on December 7, 2009, during an audit. He cited health issues, including hospitalization for high blood pressure from December 10-13, 2009, and a heavy workload during the ...
Case Digest (A.M. No. MTJ-11-1793)
Facts:
Filing of the Complaint: On February 21, 1994, Antonio Y. Cabasares filed a Complaint for Malicious Mischief against Rodolfo Hebaya, docketed as Criminal Case No. 8864, before the Municipal Trial Court in Cities (MTCC), 8th Judicial Region, Calbayog City, Western Samar, presided over by Judge Filemon A. Tandinco, Jr.
Submission for Decision: The case was submitted for decision on February 27, 2002.
Delay in Rendering Decision: Despite the case being submitted for decision, no decision was rendered by the time Cabasares filed an administrative complaint on November 6, 2009, alleging undue delay in rendering a decision.
Respondent Judge's Explanation: In his Comment, Judge Tandinco claimed that he only became aware of the administrative complaint on December 7, 2009. He explained that he was hospitalized for high blood pressure from December 10-13, 2009, and was on leave until December 17, 2009. He returned to work on December 18, 2009, but due to the Christmas season and heavy workload, the case slipped his mind. A decision was eventually prepared and promulgated on January 14, 2010.
Retirement: Judge Tandinco retired on January 15, 2010.
Issue:
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Ruling:
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Ratio:
Constitutional and Ethical Obligations: Section 15(1), Article VIII of the 1987 Constitution mandates that lower courts must decide or resolve cases within three (3) months from the date of submission. Canon 3, Rule 3.05 of the Code of Judicial Conduct similarly requires judges to dispose of court business promptly and to decide cases within the required period.
Failure to Comply: Judge Tandinco failed to render a decision within the 90-day reglementary period and did not request an extension of time. The Court emphasized that requests for extensions must be made before the expiration of the reglementary period, and failure to do so constitutes a violation of constitutional and ethical obligations.
Inexcusable Delay: The Court rejected Judge Tandinco's explanation that his health condition and heavy workload caused the delay. The case had been pending for decision long before his hospitalization in 2009. His admission that the case "may have escaped his mind" demonstrated a lack of an effective court management system.
Administrative Sanctions: Under Sections 9 and 11, Rule 140 of the Rules of Court, undue delay in rendering a decision is classified as a less serious charge, punishable by suspension or a fine. Since Judge Tandinco had already retired, the Court imposed a fine of P11,000.00, considering the extent of the delay.
Judicial Reminder: The Court reiterated the importance of promptness in the administration of justice, as undue delay erodes public confidence in the judicial system and may provoke suspicions of ulterior motives.
Conclusion:
The Supreme Court found Judge Filemon A. Tandinco, Jr. guilty of undue delay in rendering a decision and imposed a fine of P11,000.00, to be deducted from his retirement benefits. The decision serves as a reminder to all judges to adhere to the constitutional and ethical obligations of prompt case disposition.