Case Digest (A.M. No. 98-12-394-RTC)
Facts:
- Judge Benjamin A. Bongolan served in the Regional Trial Court (RTC), Branch 2, in Bangued, Abra.
- He was compulsorily retired on August 28, 1998.
- An audit by the Office of the Court Administrator (OCA) commenced on November 4, 1998, to evaluate pending cases in his court.
- The audit concluded on November 17, 1999, revealing Judge Bongolan's failure to decide four criminal cases and twenty-seven civil cases, among others.
- A memorandum from Court Administrator Alfredo L. Benipayo recommended a fine of P10,000 from Judge Bongolan's retirement benefits due to his failure to resolve thirty-one cases.
- Judge Bongolan attributed his performance issues to illness during his final year, but the court found this explanation insufficient.
Issue:
- (Unlock)
Ruling:
- The Supreme Court found Judge Benjamin A. Bongolan guilty of undue delay in managing his cases.
- A fine of P15,000 was imposed, to be deducted from his retirement benefits.
- The court determin...(Unlock)
Ratio:
- The ruling was grounded in the constitutional mandate for trial judges to resolve cases within three months, as outlined in Section 15(1), Article VIII of the 1987 Constitution.
- The court highlighted the significance of timely case resolution and its effect on public trust in the judiciary.
- Although Judge Bongolan's illness was recognized, it was considered ...continue reading
Case Digest (A.M. No. 98-12-394-RTC)
Facts:
This case involves Judge Benjamin A. Bongolan, who served as a judge in the Regional Trial Court (RTC), Branch 2, located in Bangued, Abra. He was compulsorily retired from his position on August 28, 1998. Following his retirement, on November 4, 1998, the Office of the Court Administrator (OCA) initiated an audit to conduct a judicial audit and a physical inventory of pending cases in his court. The audit was completed on November 17, 1999, and it revealed that Judge Bongolan had failed to render decisions within the reglementary period for a significant number of cases. Specifically, he had not decided four criminal cases and twenty-seven civil cases, along with several matters that had been submitted for resolution. In response to these findings, a memorandum dated December 10, 1999, was issued by then Court Administrator Alfredo L. Benipayo, recommending that a fine of P10,000 be withheld from Judge Bongolan's retirement benefits due to his failure to decide thirty-one cases within the required timeframe. Judge Bongolan later contended that his illness during his final year of service significantly impacted his ability to address these undecided cases. However, the court deemed this explanation unsatisfactory, stressing that while illness could mitigate liability, it did not ab...