A.M. No. 06-9-525-RTC - Re: Report on the Judicial Audit Conducted in the RTC Branches 72 and 22, Narvacan, Ilocos Sur

The administrative case stemmed from a judicial audit and the subsequent inventory of cases in the Regional Trial Court (RTC) of Narvacan, Ilocos Sur.
The audit was conducted in two branches—Branch 72 (the regular court of Judge Buenavista) and Branch 22 (where he acted as a pairing judge)—prior to his retirement on May 20, 2006.

The audit team from the Office of the Court Administrator (OCA) reported that as of April 5, 2006, Branch 72 had a caseload of 333 cases, composed of 126 civil cases and 207 criminal cases.
In Branch 22, the caseload amounted to 302 cases, with 106 civil cases and 196 criminal cases.
The report revealed that numerous cases submitted for decision exceeded the mandatory 90-day reglementary period, with several experiencing minimal delays while a few were resolved only after the audit.
Additionally, there were instances where no action was taken since filing or where the cases stagnated for unreasonable periods, with delays stretching back to as early as the year 2000.

Judge Buenavista attributed the delays partly to personal hardships, specifically the death of his wife a year before the audit.
He cited his gradually failing eyesight as another contributing factor.
His responsibilities were compounded by his simultaneous role as the presiding judge in Branch 72 and pairing judge in Branch 22.

The audit team concluded that Judge Buenavista did not exercise sufficient control over the cases under his supervision.
The failure to manage the docket effectively resulted in unreasonable delays in the disposition of many cases, thereby clogging the court’s docket and undermining judicial efficiency.

In a Memorandum dated August 10, 2006, the OCA recommended that Judge Buenavista be fined P10,000.00.
The penalty was based on his failure to decide twelve cases and resolve incidents in seven cases within the prescribed reglementary period.
The recommendation took into account mitigating circumstances such as his personal loss, his health issues, his dual-branch responsibilities, and his otherwise diligent disposal of twenty-five cases before retirement.
Notably, records showed that apart from one instance where an extension was sought, Judge Buenavista did not request extensions for the delayed cases.

The central issue is whether Judge Buenavista should be subjected to the penalty recommended by the OCA for his failure to perform his official duties assiduously.

Whether the delay in deciding cases, in excess of the constitutional 90-day period, amounts to gross inefficiency.
Whether the mitigating circumstances (personal tragedy, failing eyesight, and dual assignments) are sufficient to excuse the administrative lapses.
The appropriateness of imposing a fine as a sanction without a substantial showing of cause for an extension in most instances.