G.R. No. L-49549 - Chua-Qua vs. Clave

An audit and physical inventory was conducted on 11 and 12 May 1994 at the Regional Trial Court, Branch 8, Tanauan, Batangas.
The audit covered both criminal and civil cases pending in the sala of Judge Liberato C. Cortes, including those submitted for decision and/or resolution.

The total caseload in Branch 8 was recorded at 386 cases.
Of the total cases, 196 were criminal cases and 190 were civil cases.
It was noted that in 15 criminal cases and 32 civil cases, no action had been taken for a long period.

Two criminal cases had already been submitted for decision on 10 August 1993 and 14 October 1993 respectively.
Despite their submission, these cases remained undecided as of the audit date.

On 21 June 1994, the Court issued a resolution requiring Judge Cortes to explain:

His failure to act on the cases despite significant delays.
The reasons for not deciding the cases submitted for decision within the reglementary period.

Judge Cortes was directed to resolve all unresolved cases within 90 days and to temporarily cease hearing new cases.
Consideration was given to reassigning the sala to a newly-appointed judge (either Judge Emma L. Reyes or Judge Paterno V. Tac-an).

Judge Cortes admitted that his delay in resolving the cases was partly due to inadequate management of time and resources.
He cited additional factors such as:

Poor court facilities.
Inadequate research materials.
Shortcomings in stenographer services, which hampered his efforts from the beginning.

The records and the judge’s admission clearly established a pattern of dismal and sluggish case resolution in his sala.
Previous jurisprudence (e.g., Nidua v. Lazaro, Sabado v. Cajigal, Alfonso-Cortes v. Maglalang) was cited to underscore the necessity for prompt judicial action and efficient court management.

The Office of the Court Administrator recommended a disciplinary fine equivalent to one-month salary.
Ultimately, considering the gravity of inaction and previous reprimands, a fine of ₱15,000.00 was imposed.
Judge Cortes was ordered to pay the fine within 30 days from receipt of the notice, with a stern warning that any future delay would result in a more severe penalty.
A copy of the resolution was to be attached to the official records of Judge Cortes on file with the Court.

Was Judge Cortes justified in his failure to act on the pending cases despite the long delays?
Could his cited reasons, such as inadequate facilities and insufficient personnel support, excuse his inaction?

Does the court’s recommendation to reassign a newly-appointed judge indicate systemic issues in case management?
To what extent can administrative shortcomings be mitigated in holding a judge accountable for case disposition?

Is it acceptable for cases submitted for decision to remain undecided beyond the prescribed time limits?
How do established rules (e.g., Rules 3.01 and 3.05 of the Code of Judicial Conduct) influence the expectations for speedy disposition?

How do prior decisions (such as Nidua v. Lazaro, Sabado v. Cajigal, and Alfonso-Cortes v. Maglalang) inform the assessment of Judge Cortes’ performance?
What legal standards are applied in determining whether the delay constitutes gross neglect of duty?

Is a fine of ₱15,000.00 a proportionate penalty given the circumstances and past record of delay?
How does the fine serve as a deterrent against future judicial dilatoriness?