G.R. No. 148635 - Cavile vs. Heirs of Cavile

On 13 June 2011, a judicial audit was conducted at the Regional Trial Court (RTC), Branch 49, Tagbilaran City, presided over by Judge Fernando G. Fuentes III.
The audit report revealed:

A total of 272 pending cases in the docket, comprising 138 criminal and 134 civil cases.
Of these, 83 cases (24 criminal and 59 civil) were submitted for decision.
Out of the 83 submitted cases, 70 cases were already beyond the reglementary period, with some dating back as far as 2003.
Among these 70 cases, 31 were appeal cases from first level courts, which included two criminal cases involving detention prisoners.

Cease hearing new cases and devote his time to resolving the backlog, giving priority to criminal cases involving detention prisoners.
Provide copies of decisions/orders for the pending cases to the Office of the Court Administrator (OCA).
Have his salaries, allowances, and other benefits withheld until full compliance with the directive.

The resolution also mandated a resolution of 27 pending incidents/motions.
It required the judge to submit a written explanation within 15 days on why no administrative sanction should be imposed for his failure to decide or resolve the 83 cases and 27 pending motions.

The Court designated Presiding Judge Suceso A. Arcamo (RTC, Branch 47, Tagbilaran City) as the assisting judge for RTC, Branch 49, to conduct hearings and address interlocutory matters until full compliance by Judge Fuentes III.
Atty. Fara Ricarda Paras-Matuod, Branch Clerk of Court for RTC, Branch 49, was directed to apprise the judge of cases with no further action and to adjust the court calendar for cases with pending proceedings.

Acknowledged the adverse findings of the audit.
Cited his non-residence in Bohol (being based in Ozamis City) and cited family-related issues, including the hospitalization of his autistic child, as reasons for the delay.
Expressed gratitude for the opportunity to resolve his backlog, commiting to comply with the court’s directive.

On 13 March 2012, partial compliance was demonstrated when the judge submitted copies of his decisions/orders for 39 civil and 21 criminal cases.
He requested an extension until 16 April 2012 to fully comply with the directives.
Further submissions were made on 9 July 2012, when additional copies of decisions (23 civil and 5 criminal cases) and 20 orders were submitted.
On 16 July 2012, Judge Fuentes III requested yet another extension, stating that his youngest son’s illness had affected his ability to act within the previously extended period.

On 21 September 2011, Paulino Butal, Sr. filed a verified complaint against Judge Fuentes III regarding undue delay in rendering a decision in Civil Case No. 7028.
The complaint detailed:

The termination of the trial on 28 January 2008.
The submission of memoranda by the parties within the required periods.
A subsequent motion pleading for judgment after 17 months had passed since submission for decision.

In his comment dated 28 October 2011, Judge Fuentes III admitted the delay in the said case and attached a copy of his decision rendered on 20 October 2011.

On 23 April 2012, the Court adopted the findings of the OCA by re-docketing the administrative matter (originally A.M. No. 11-8-152-RTC) as A.M. No. RTJ-12-2318 and consolidated it with matters pertaining to Civil Case No. 7028.
In its report dated 19 November 2012, the OCA recommended:

Finding Judge Fuentes III guilty of gross inefficiency for failing to decide 70 cases and to resolve 27 pending incidents/motions.
Imposing a fine of P50,000 (later adjusted) and issuing a stern warning.
Highlighting that the duty of a judge is not only to hear cases but also to render timely decisions as mandated under law.

The Court, considering the prior record and earnest efforts toward compliance, reduced the fine imposed.
Judge Fuentes III was fined P40,000 and sternly warned that any repetition of similar offenses would attract more severe sanctions.
The Financial Management Office was directed to release the withheld salaries, allowances, and benefits (after deducting the imposed fine).
The matter concerning Atty. Paras-Matuod was declared closed and terminated.
The temporary designation of the assisting judge was revoked.

Whether Judge Fuentes III’s failure to decide 70 cases and resolve 27 pending motions within the prescribed reglementary period amounts to gross inefficiency.
Whether the delay in rendering judgment in Civil Case No. 7028 constitutes a separate infraction or is part of the overall failure to timely decide cases.

Whether Judge Fuentes III’s claims of non-residence in Bohol and personal or family health issues (notably his son’s hospitalization) serve as valid justifications for the delays in case disposition.
Whether the absence of timely and proper extension requests before the audit affects the legitimacy of his justifications.

Whether the imposition of a fine, withholding of benefits, and issuance of a stern warning are appropriate and proportionate responses in light of the alleged inefficiencies.
Whether the measures taken adequately address the broader principle of judicial accountability and promptness.