Facts:

The case involves Judge Felix S. Caballes, who presided over the Regional Trial Court, Branch 71, in Antipolo City. On November 7, 2003, a judicial audit team from the Office of the Court Administrator conducted an inventory of cases in Judge Caballes' court. The audit revealed that he had failed to decide 29 criminal cases and 21 civil cases within the mandated ninety (90) days. Additionally, he did not resolve motions or pending incidents in these cases and failed to take further action in 92 other cases. Following the audit, the team recommended that Judge Caballes be required to explain why he should not face administrative sanctions for his inaction and suggested withholding ₱100,000 from his retirement benefits until he provided an explanation. The Supreme Court adopted this recommendation in a resolution dated January 19, 2004. In response, Judge Caballes submitted a letter on March 22, 2004, explaining that his failure to act on the cases was not due to negligence...

Facts:

Judicial Audit Findings

• On November 7, 2003, the judicial audit team of the Office of the Court Administrator conducted an inventory of cases in the Regional Trial Court (RTC), Branch 71, Antipolo City, presided over by Judge Felix S. Caballes.
• The audit revealed that Judge Caballes failed to:
  1. Decide 29 criminal cases and 21 civil cases within the 90-day reglementary period.
  2. Resolve motions/pending incidents in cases within the prescribed period.
  3. Take further action in 92 cases.

Recommendation of the Audit Team

• The team recommended that Judge Caballes be required to explain why no administrative sanction should be imposed on him for these failures.
• They also recommended withholding P100,000 from his retirement benefits pending his explanation.

Judge Caballes' Explanation

• In his letter dated March 22, 2004, Judge Caballes explained that his failure to decide and resolve cases was not due to laziness, neglect, or complacency.
• He cited the following reasons:
  1. He suffered from a heart ailment and underwent quadruple bypass surgery in 1997.
  2. His court lacked a regular appointed Clerk of Court, and the Acting Clerk of Court, though an LLB graduate, was not a full-fledged lawyer, limiting her ability to assist effectively.
  3. His court was undermanned, with only 11 personnel handling approximately 1,500 cases, compared to other courts with lighter caseloads.
  4. The small office space and lack of filing cabinets contributed to misfiling and delays.
• He appealed for fairness, kindness, and understanding, stating that his inability to resolve cases was due to circumstances beyond his control.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Prompt Disposition of Cases: Rule 3.05 of the Code of Judicial Conduct mandates judges to dispose of court business promptly and decide cases within the prescribed period. The 1987 Constitution also requires trial courts to resolve cases within three months from submission.
2. No Excuse for Delay: While the Court acknowledges the heavy caseload of judges and has been sympathetic to requests for extensions, Judge Caballes failed to request such extensions. His illness and court mismanagement are not valid excuses for undue delay.
3. Responsibility of Judges: Judges are primarily responsible for maintaining the professional competence of their staff and ensuring the efficient dispatch of court business, as stated in Rules 3.08 and 3.09 of the Code of Judicial Conduct.
4. Penalty for Delay: Under Section 9, Rule 140 of the Rules of Court, undue delay in rendering decisions is a less serious charge punishable by suspension or a fine. Given the circumstances, the Court imposed a fine of P15,000.00.