Facts:

The case involves Judge Benjamin A. Bongolan, who served in the Regional Trial Court (RTC), Branch 2, located in Bangued, Abra. He compulsorily retired on August 28, 1998. Following his retirement, the Office of the Court Administrator (OCA) dispatched an audit team on November 4, 1998, to conduct a judicial audit and physical inventory of the pending cases in his court. The audit team submitted a report on November 17, 1999, revealing that Judge Bongolan had failed to render decisions within the mandated time frame for several cases, including four criminal cases (Criminal Cases Nos. 1283, 1316, 1559, and 1782) and numerous civil cases (Civil Cases Nos. 725, 727, 805, 834, 866, 914, 928, 955, 1006, 1051, 1083, 1096, 1104, 1117, 1148, 1198, 1276, 1320, 1433, 1533, SP-0781, SP-0897, SP-1088, SP-1129, SP-1184, LRC N-23, and LRC N-24). Additionally, he had not resolved matters submitted for his resolution in Civil Cases Nos. 901, 1054, and 1385. In a memorandum dated December 10...

Facts:

1. Retirement of Judge Benjamin A. Bongolan:
   Judge Benjamin A. Bongolan of the Regional Trial Court (RTC), Branch 2, Bangued, Abra, compulsorily retired on August 28, 1998.

2. Judicial Audit and Inventory:
   On November 4, 1998, the Office of the Court Administrator (OCA) sent an audit team to conduct a judicial audit and physical inventory of cases pending in Judge Bongolan's court.

3. Findings of the Audit Team:
   The audit team submitted a report on November 17, 1999, revealing that Judge Bongolan failed to render decisions within the reglementary period in the following cases:

   • Criminal Cases: Nos. 1283, 1316, 1559, and 1782.
   • Civil Cases: Nos. 725, 727, 805, 834, 866, 914, 928, 955, 1006, 1051, 1083, 1096, 1104, 1117, 1148, 1198, 1276, 1320, 1433, 1533, SP-0781, SP-0897, SP-1088, SP-1129, SP-1184, LRC N-23, and LRC N-24.
   • Partially Tried Civil Cases: Nos. 162, 236, 286, 531, 576, 579, 689, 715, and SP-0665.
   • Unresolved Matters: Civil Cases Nos. 901, 1054, and 1385.

4. Recommendation of the Court Administrator:
   The Court Administrator recommended that the P10,000.00 withheld from Judge Bongolan's retirement benefits be forfeited as a fine for his failure to decide the cases within the 90-day reglementary period.

5. Judge Bongolan's Explanation:
   Judge Bongolan attributed his failure to decide the cases to his illness during the last year of his service.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Constitutional and Ethical Obligations:

   • Section 15(1), Article VIII of the 1987 Constitution mandates that trial judges must dispose of all cases or matters within three months.
   • Rule 3.05 of Canon 3 of the Code of Judicial Conduct requires judges to dispose of court business promptly and decide cases within the required period.

2. Illness as a Mitigating Factor:

   • While Judge Bongolan's illness may mitigate his liability, it does not completely exonerate him from his responsibility to decide cases without undue delay.
   • The Court emphasized that Judge Bongolan could have requested an extension of time from the Court to decide the cases, but he failed to do so.

3. Precedents on Delay in Decision-Making:

   • The Court cited precedents, including Re: Cases Left Undecided by Judge Narciso M. Bumanglag, Jr., which held that serious illness may justify a judge's inability to perform duties but does not absolve them from administrative liability.
   • The Court reiterated that undue delay in the disposition of cases amounts to a denial of justice, erodes public confidence in the judiciary, and constitutes gross inefficiency.

4. Penalty Imposed:

   • Under Section 9(1), Rule 140 of the Revised Rules of Court, undue delay in rendering a decision is classified as a less serious charge.
   • The penalty for such an offense is suspension without salary and benefits for one to three months or a fine of more than P10,000.00 but not exceeding P20,000.00.
   • Since Judge Bongolan had already retired, the Court imposed a fine of P15,000.00, to be deducted from his retirement benefits.