A.M. No. 97-3-85 RTC - Report on the Judicial Audit Conducted in RTC-Manila, Branch 4 and 23

A judicial audit was conducted following the compulsory retirements of the presiding judges in three courts:

The Office of the Court Administrator (OCA) carried out the audit on all pending cases, examining both civil and criminal case records.

Out of 59 civil cases examined, inconsistencies were noted between the physical records and the docket entries.
Certain cases physically examined were absent from the Docket Book, while some pending cases listed in the Docket Book showed missing records.
Cases were found to have been "submitted for decision" beyond the 90-day reglementary period with several cases detailed by their docket numbers (e.g., 94-69553, 91-59300, 93-68026, etc.).

The Audit Team examined 52 criminal cases with some cases filed or dismissed in January 1997 and others archived.
The process revealed similar problems with the Docket Book as observed in the civil cases, making it an unreliable source for accurate case tracking.

Only 80 records of pending civil cases were physically examined.
Court employees repeatedly indicated that certain records were housed inside Judge Salamanca’s chambers.
The Branch Clerk of Court was unable to produce these records despite repeated requests, leading to the conclusion that Judge Salamanca intentionally withheld them from the audit.

A list of civil cases was identified where records were not physically examined, including multiple docket numbers and corresponding case details spanning from older cases (dating back to 1979) to more recent filings in 1996.
Certain cases were noted as having been submitted for decision beyond the limit despite extended delays or inadequate resolution.

Judge Bayhon was ordered to render decisions on cases pending beyond the 90-day period and to explain the delay in addressing a list of cases.
Judge Salamanca was similarly directed regarding cases pending beyond the prescribed period as well as an explanation for retaining case records after his retirement.
Both branch clerks were ordered to account for discrepancies and failures in proper docket record management, in violation of Sections 7 and 8 of Rule 136 of the Rules of Court.

In a letter dated July 18, 1997, Judge Bayhon submitted proofs that decisions in several cases had been rendered, while noting that some cases remained on trial.
Judge Bayhon did not adequately explain why no court action was taken on a considerable number of cases.
Judge Salamanca explained that his records were rendered irretrievable due to alleged physical deterioration (termite damage and water leakage) in a condemned building; however, his explanation was deemed insufficient.

Identification of inefficiencies in the management of docket records in both the RTC and MeTC branches.
Highlighting of judicial negligence evidenced by the failure to dispose of cases within the constitutionally mandated period.
The OCA recommended steep fines (initially P50,000 each) for the respective judges and for the clerks’ violations of the Rules of Court.

The Court recognized the gross inefficiency and neglect of duty on the part of the judges.
Notwithstanding the disappointing performance and the previous recommendations, a reduction of the penalties was granted in view of the judges’ retirements and lack of prior adverse records.
The final resolution imposed fines of P10,000 each on Judge Bayhon and Judge Salamanca, with an additional P10,000 fine specifically on Judge Salamanca for the unauthorized retention of case records.

Whether the actions and inactions of Judges Bayhon and Salamanca constituted gross inefficiency and neglect of duty by failing to dispose of cases within the 90-day reglementary period.
Whether the maintenance, recording, and safeguarding of court records, as required by the Rules of Court, were compromised by the discrepancies in the Docket Book and the refusal to produce records.
Whether the justifications and excuses provided by the judges, including the claim of additional responsibilities as an Executive Judge and the physical deterioration of records, were acceptable under judicial norms.
The extent to which the branch clerks of court contributed to the disorder and whether their non-cooperation constitutes a separate violation warranting disciplinary action.
How judicial accountability should be imposed when administrative audits reveal significant lapses in court management and case resolution.