Title
Supreme Court
Re: Result of the Judicial Audit Conducted in Branch 49, Regional Trial Court, Puerto Princesa City, Palawan
Case
A.M. No. 19-12-293-RTC
Decision Date
Jun 30, 2020
Judge Legazpi fined P50,000 for gross inefficiency due to delayed case resolutions, despite mitigating factors like heavy caseload and health issues.

Case Digest (A.M. No. 19-12-293-RTC)
Expanded Legal Reasoning Model

Facts:

  • Judicial Audit Conducted
    • A judicial audit was conducted in March 2014 in Branch 49 of the Regional Trial Court (RTC) in Puerto Princesa City, Palawan.
    • The audit was carried out when Judge Leopoldo Mario P. Legazpi was presiding over the branch.
    • The audit findings were documented in a Memorandum dated 20 January 2015 by Deputy Court Administrator Raul Bautista Villanueva.
  • Findings of the Audit Report
    • There were 88 cases submitted for decision, with 79 cases exceeding the reglementary period for decision.
    • Fifty-one cases had pending incidents for resolution, with 40 of these beyond the prescribed period.
    • Forty-nine cases had been inactive with no further action or scheduling for an unreasonably long time.
    • Three cases showed no initial action.
    • Twenty-four cases were due for archiving pursuant to OCA Circular No. 89-2004.
    • It was noted that:
      • The cases were not properly reflected in the Monthly Report of Cases.
      • No record existed showing that Judge Legazpi had requested an extension of time to decide the cases.
      • There was also a delay in deciding appealed cases, in violation of Section 7, Rule 40 of the Rules of Court.
  • Directives Issued to Judge Legazpi
    • Judge Legazpi was instructed to:
      • Decide the 88 cases submitted for decision.
      • Resolve the 51 pending incidents.
      • Take appropriate action on the 49 inactive cases.
      • Take appropriate action on the 3 cases with no initial action.
      • Take action on the 24 cases due for archiving.
      • Address additional findings as stated in the memorandum.
      • Provide explanations regarding:
        • Failure to decide within the reglementary period.
ii. Non-filing of extension requests. iii. Inadequate reporting of cases in the Monthly Report and Semestral Docket Inventory Reports.
  • Complete and accurately submit the requisite reports (Monthly Report of Cases and Semestral Docket Inventory Report) as prescribed by the Court guidelines.
  • Submit copies of pertinent decisions, orders, and relevant reports as proof of compliance.
  • Judge Legazpi’s Explanation and Circumstances
    • Submission of Written Explanation
      • On 2 March 2015, Judge Legazpi explained his failure to decide the cases promptly and the lack of extensions.
      • He attributed the delays to:
        • A backlog of cases inherited from predecessors, including cases pending trial for over five years.
ii. An attempt to expedite trials through a strict trial calendar system that curtailed postponements, resulting in:
  • Increased number of cases scheduled per trial date.
  • Longer trial days with expedited presentations.
  • Multiple transcriptions by stenographers due to intensified work.
iii. A heavy caseload where he had to decide both newly submitted and long-pending cases concurrently.
  • Administrative and Staffing Challenges
    • Administrative functions were delegated to the Branch Clerk of Court and clerks, while Judge Legazpi focused solely on judicial work.
    • Lack of adequate personnel:
      • Extended vacancies in Branch 51 for five years and in Branch 52 for nearly two years.
ii. Insufficient office staff, absence of a permanent clerk of court (the initial clerks served only six months, and the third resigned in August 2014). iii. Lack of a legal researcher and a clerk-in-charge of criminal cases during critical periods. iv. Shortage of stenographers following retirements, coupled with delayed appointments despite earlier requests.
  • Health Concerns
    • Judge Legazpi suffered from diabetes and related complications exacerbated by work stress.
    • His surgical procedure for a neck tumor had to be deferred due to unstable blood sugar and blood pressure.
    • These health issues further impacted his ability to manage the heavy workload.
  • Resignation and Subsequent Developments
    • On 22 January 2015, Judge Legazpi submitted a resignation letter effective 15 March 2015 citing health reasons.
    • The Office of the Court Administrator (OCA) later recommended acceptance of his resignation, subject to clearance requirements.
    • In a Memorandum dated 13 November 2019, the OCA re-docketed the matter as a regular administrative case and recommended:
      • Finding Judge Legazpi guilty of gross inefficiency.
ii. Imposing a fine of P50,000.00, to be either deducted from his accrued leave credits or paid directly.

Issues:

  • Whether or not Judge Legazpi should be held administratively liable for gross inefficiency due to:
    • The failure to decide or resolve the cases within the reglementary period.
    • The failure to seek lawful extensions despite encountering heavy caseloads and staffing deficiencies.
  • Whether the mitigating circumstances such as heavy workload, lack of personnel, and health issues can justify his delay in rendering decisions and managing administrative responsibilities.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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