Case Digest (A.M. No. RTJ-15-2432)
Facts:
Office of the Court Administrator v. Presiding Judge Buenaventura A. Pajaron, A.M. No. RTJ-15-2432 (Formerly A.M. No. 15-06-195-RTC), October 06, 2021, Supreme Court Third Division, Zalameda, J., writing for the Court.The case arose from an 08 August 2014 letter by Atty. Isagani S. Espada, then Clerk of Court of RTC Branch 10, Abuyog, Leyte, reporting a backlog of cases submitted for decision before Presiding Judge Buenaventura A. Pajaron (respondent). The Office of the Court Administrator (OCA) audited monthly reports and semestral docket inventories for January 2013 to October 2014 and found numerous cases submitted for decision as early as 2011 that remained undecided beyond the reglementary period. The audit identified sixty-six (66) unresolved cases (forty-three criminal and twenty-three civil), some delayed for at least three years.
The OCA ordered respondent to explain why he should not be held administratively liable for gross neglect and gross inefficiency. In his 04 December 2014 Explanation, respondent attributed delays to lack of personnel, the resignation/abandonment of the clerk after Super Typhoon Yolanda (08 November 2013), power and operational disruptions, and his own medical condition, and he stated he disposed of twenty-two cases in October–November 2014. The OCA’s Resolution of 05 August 2015 re-docketed the matter as a regular administrative case, instructed Judge Pajaron to cease trials and decide all overdue cases within 90 days, required copies of decisions, designated Presiding Judge Carlos O. Arguelles as Assisting Judge for Branch 10, and directed both Judge Pajaron and Atty. Espada to explain alleged false reporting.
Respondent filed a supplemental Explanation on 05 November 2015 (received 14 January 2016), reiterating his earlier defenses and claiming some decisions were submitted to the OCA. Records later showed Atty. Espada had resigned effective 31 August 2014 (acceptance on 07 September 2015). A manifested filing by Atty. Espada dated 25 October 2016 was received 12 January 2017 but not appended to the records. Respondent compulsorily retired on 30 December 2015.
In a Memorandum dated 18 January 2019, the OCA recommended a finding of guilt for gross neglect, gross inefficiency and dishonesty; a fine of Php200,000.00; the return of specified case records; and directions to the Acting Presiding Judge to decide certain submitted cases and to reconstitute records if necessary. The OCA anchored its recommendations on the constitutional duty to decide cases within three months (Section 15(1), Article VIII, 1987 Constitution), the New Code of Judicial Conduct, and applicable provisions o...(Subscriber-Only)
Issues:
- Is respondent administratively liable for gross inefficiency and dishonesty for failing to decide cases within the reglementary period and for certifying he had resolved incidents when unresolved cases existed?
- What penalty and ancillary directives should the Court impose for the established ad...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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