Case Digest (A.M. No. RTJ-21-005)
Facts:
Office of the Court Administrator, Complainant, vs. Hon. Evelyn A. Atienza-Turla, Presiding Judge, Branch 40, Regional Trial Court, Palayan City, Nueva Ecija, A.M. No. RTJ-21-005 (Formerly A.M. No. 20-11-161-RTC), December 09, 2020, the Supreme Court En Banc, Gaerlan, J., writing for the Court.The matter arose from a judicial audit and physical inventory of cases conducted at the Regional Trial Court, Branch 40, Palayan City, Nueva Ecija, held from January 31, 2019 to February 23, 2019 pursuant to Travel Order No. 12-2019 (Jan. 18, 2019). The audit team reported that the court, then presided by Judge Evelyn A. Atienza-Turla (who availed of terminal leave Nov. 1, 2018 and compulsorily retired March 18, 2019), had a total caseload of 833 cases (666 criminal, 167 civil). The team found numerous instances of delays: criminal and civil cases submitted for decision that exceeded the reglementary period, pending incidents unresolved for considerable time, cases ripe for archiving or issuance of alias warrants left unattended, and numerous decisions and orders rendered beyond the period to decide without any proof of extension requested from the Office of the Court Administrator (OCA).
The audit also documented systemic mismanagement of court records and proceedings: interruptions to continuous trial, lack of corresponding orders, failure to state case status in notices/orders, delays in producing minutes and stenographic notes, failure to maintain case indexes and proper pagination, improper use of detainees' notebooks, clerical errors in names and dates, lack of proof of mailing on orders/decisions, excessive court-initiated resettings, and failure to use the OCA docket inventory format. On February 22, 2019 the audit team's scheduled exit conference found almost all court employees absent (except a utility worker); the logbook showed many unfilled entries and the employees later reported they had attended a marathon in Cabanatuan City. The audit team documented these observations with photographs and logbook copies attached to its Judicial Report.
On October 26, 2020 the OCA sent a memorandum to Chief Justice Peralta transmitting the Judicial Report (dated Oct. 2, 2020) and recommending: re-docketing the matter as a regular administrative case against retired Judge Atienza-Turla; finding her GUILTY of the less serious charge of undue delay in rendering decision or order under Section 9 and 11, Rule 140 of the Rules of Court and Rule 3.05 of Canon 3 of the Code of Judicial Conduct; imposing a penalty (suspension or fine) but, given the judge’s retirement, imposing a fine equivalent to three months’ salary to be deducted from retirement/gratuity benefits; directing several court employees to explain their absences at the exit conference and present any authority for such absences; and ordering the Officer-in-Charge to update records, attach proofs of service/mailing, expedite disposition of stale cases, submit quarterly status reports, and comply with Administrative Circulars No. 76-2007 and No. 61-2001 (monthly/semestral reporting requirements).
The Court reviewed the OCA findings and recommendations, agreed with them, and proceeded to adjudicate the administrative charge against Judge Atienza...(Pro-only)
Issues:
- Did Judge Evelyn A. Atienza-Turla commit the less serious administrative offense of undue delay in rendering decisions or orders by failing to decide/resolving numerous cases and motions within the reglementary period?
- If guilty, what administrative sanction is proper given that Judge Atienza-Turla had already retired?
- Should the court employees who were absent during the audit team's exit confe...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)