A.M. No. 00-3-48-MeTC - Report on the Judicial Audit and Physical Inventory of Cases in the Municipal Trial Court of Manila Branch 2

An audit was triggered by Judge Rolando B. de Guzman’s repeated failure to submit mandated monthly reports (January–December 1999) and the semestral docket inventory ending June 1999 for the Metropolitan Trial Court of Manila, Branch 2.
The Office of the Court Administrator (OCA) had earlier directed the withholding of salaries from Judge de Guzman and the Branch Clerk, Rosario C. de Guzman, as a consequence of these omissions.

Conducted from January 17–21, 2000, the judicial audit and physical inventory revealed:

Mismanagement of case records, with civil cases mixed with criminal cases.
Inadequate and improperly maintained docket books where vital data were omitted, and orders in open court were left unsigned.
A failure to adopt proper archiving procedures—resulting from non-observance of Administrative Circular No. 7-92—which led to pending, disposed, and archived cases being improperly bundled.

The audit reported a total of 3,410 cases (2,872 criminal and 538 civil), with numerous cases at various stages such as submitted for decision, submitted for resolution, on trial, pending pre-trial, and others, as well as cases with unacted incidents and unsigned decisions.

On May 10, 2000, the Court issued a comprehensive resolution directing Judge de Guzman to:

Inform and explain delays in decisions for specific enumerated cases and failures in executing court orders such as signing dismissals.
Resolve pending cases and submit detailed performance reports within set deadlines.

Specific instructions extended to the Branch Clerk and the Financial Management and Budget Office, including the immediate release or continued withholding of salaries based on compliance.

The respondent submitted his Manifestation-Explanation in October 2000 and again in September 2001, which the Court found unsatisfactory.
On September 3, 2001, the Court reiterated its directives, instructing Judge de Guzman to cease hearing new cases temporarily and instead focus on resolving those already submitted.
The respondent later filed a motion to reconsider, claiming that he had complied with the directives, supported by certifications indicating the timely submission of reports and docket inventories.
A second judicial audit, conducted in July 2002, revealed:

Numerous continuing deficiencies, including a significant number of undecided cases, unresolved incidents, and unsigned decisions/orders, some dating back to as early as 1997.
Persistent mismanagement in the archiving of cases, with many cases ready for archiving remaining unarchived or with unsigned archival orders.

On February 14, 2003, the OCA recommended dismissal of Judge de Guzman for gross neglect of duty, inefficiency, and indifference in performing his judicial responsibilities.
The matter was subsequently treated as an administrative complaint, with additional directions for further compliance regarding pending reports and case resolutions.

Whether Judge de Guzman’s failure to submit required monthly reports and docket inventories constitutes a dereliction of judicial duty.
Whether the mismanagement and improper archiving of case records materially contributed to delays in decision-making and disposition of cases.
Whether the respondent’s heavy caseload and claims of being undermanned provide a legally acceptable excuse for his failure to comply with statutory and administrative mandates.
Whether the imposed administrative sanctions, including dismissal from service, are justified based on the proven instances of inefficiency and neglect.