Facts:

This case, titled "Re: Report on the Judicial Audit and Physical Inventory of Cases Conducted in the Regional Trial Courts of Davao City," arose from a judicial audit and physical inventory of pending cases in ten Regional Trial Courts in Davao City, specifically Branches 8 to 17, conducted from March 21 to March 30, 1994. The audit team was led by Atty. Bartolome V. Flores. The case was filed as Administrative Matter No. 94-5-178-RTC. The Supreme Court issued a resolution on November 24, 1994, directing the judges of the aforementioned branches to submit written reports on the status of cases pending before them. Judge William M. Layague of Branch 14 was specifically instructed to explain why he should not face administrative sanctions for failing to resolve 67 cases submitted for decision and 46 cases submitted for resolution within the mandated 90-day period.

By February 1995, nine out of the ten judges complied with the resolution, but Judge Layague failed to...

Facts:

Background of the Case

This case arose from a judicial audit and physical inventory of cases pending in ten (10) Regional Trial Courts (RTC) of Davao City, specifically Branches 8 to 17, conducted from March 21 to 30, 1994. The audit was led by Atty. Bartolome V. Flores. The audit revealed significant delays in the resolution of cases, particularly in Branch 14, presided over by Judge William M. Layague.

Initial Findings and Court Directives

On November 24, 1994, the Supreme Court issued a resolution directing the judges of RTC Davao City (Branches 8 to 17) to submit written reports on the status of cases submitted for decision or resolution. Judge Layague was specifically ordered to explain his failure to decide/resolve 67 cases submitted for decision and 46 cases submitted for resolution within the 90-day reglementary period. He was also directed to cease hearing new cases and focus on resolving the backlog. His salary was withheld pending compliance.

Judge Layague’s Compliance and Explanations

Judge Layague filed his compliance on October 11, 1995, attributing the delays to his frail health, including acute erosive and atrophic gastritis, emphysema, thyroid nodule, vertigo, and numbness in his lower extremities. He also cited staffing issues, such as the departure of his Branch Clerk of Court, Legal Researcher, and stenographers, which hindered his ability to resolve cases promptly. He reported disposing of 87 cases, leaving 52 unresolved, and requested until December 31, 1995, to resolve them.

Subsequent Audit Findings

A follow-up audit conducted in July 1996 revealed that Judge Layague had resolved 80 of the 147 cases initially reported as unresolved. However, 34 cases remained undecided, and an additional 41 cases were discovered to be beyond the 90-day reglementary period. The audit team also noted inefficiencies in case management, including unserved writs of execution and cases left dormant for extended periods.

Issue:

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Ruling:

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Ratio:

1. Administrative Liability for Delay in Case Resolution: Judges are mandated to decide cases within the 90-day reglementary period under the Constitution and the Rules of Court. Failure to do so constitutes gross inefficiency and warrants administrative sanctions.
2. Mitigating Factors: While the Court acknowledged Judge Layague’s health issues and staffing problems as mitigating factors, these were insufficient to fully excuse the extensive delays, especially given the number of unresolved cases.
3. Appropriateness of Sanctions: The Court imposed a fine of P25,000.00, considering the gravity of the delays and the number of cases involved. This amount was deemed reasonable compared to previous cases where lesser fines were imposed for fewer unresolved cases.
4. Importance of Timely Justice: The Court emphasized that delays in the administration of justice erode public confidence in the judiciary and must be addressed promptly and decisively.