A.M. No. 02-8-441-RTC - Report on the Judicial Audit Conducted in the RTC Branch 22, Kabacan, North Cotabato

Presiding Judge Braulio L. Hurtado of RTC, Branch 22, Kabacan, North Cotabato was set to retire compulsorily on August 27, 2002.
In anticipation of his retirement, the Office of the Court Administrator (OCA) dispatched an audit team to conduct a judicial audit and a physical inventory of the pending cases in his court.

The audit, conducted on July 9, 2002, revealed that RTC Branch 22 had a total of 274 cases pending—comprising 221 criminal cases and 53 civil cases.
Among these, 70 criminal cases and 4 civil cases had already been submitted for decision, while additional cases had pending incidents for resolution.
Specific cases (e.g., Criminal Case Nos. 96-45, 919, 01-15, 39, 99-112, 99-113) were noted as having been pending for a considerable length of time, and some cases (e.g., Criminal Case No. 01-32 and Civil Case Nos. 377, 97-08) were considered for archival in accordance with Administrative Circular guidelines.

In response to the OCA’s recommendations, the Court issued a Resolution on September 2, 2002 directing Judge Hurtado to:

Inform within ten (10) days whether Criminal Case No. 02-114 had been promulgated as scheduled (set for July 16, 2002).
Explain inadequacies in his failure to decide a substantial number of criminal and civil cases within the reglementary period.

The resolution also directed the Clerk of Court and the designated Acting Presiding Judge to provide status updates and to take appropriate action on cases that had been pending for an unreasonable length of time.

The decision in Criminal Case No. 02-114 was promulgated as scheduled.
Various pending incidents and cases were either resolved, set for further proceedings, or explained by the fact that some cases involved only one accused or were affected by his temporary assignment as Acting Presiding Judge of Surallah for six months.

The Officer-in-Charge, Branch Clerk of Court (Ms. Sarah Joy Bona), also filed a written explanation detailing the status of several criminal and miscellaneous cases.
Acting Presiding Judge Francis E. Palmones, Jr. furnished his own written explanation regarding the forwarding and scheduling of several cases, including the transfer of some for appropriate action.

In separate resolutions dated December 9, 2002, the Court noted the compliance of the concerned parties and referred the matter to the OCA for further evaluation.
On March 24, 2003, the OCA recommended imposing a fine of Fifty Thousand Pesos (P50,000.00) against Judge Hurtado, deducible from his retirement benefits, due to his failure to decide 70 criminal cases within the reglementary period.
The OCA found his justification regarding his temporary assignment as Acting Presiding Judge unsatisfactory, noting discrepancies in the timeline relative to when most pending cases became due for decision.

Whether Judge Hurtado’s failure to decide the pending cases within the mandated reglementary period constitutes gross inefficiency and neglect of duty.
Whether his explanation for delaying the decisions—attributing it to his assignment as Acting Presiding Judge elsewhere—sufficiently accounts for the lapse in performance.

Whether the directives issued in the Resolution dated September 2, 2002 were complied with in a manner that met the required standards.
Whether the subsequent submissions by the Clerk of Court and Acting Presiding Judge Palmones adequately remedied the concerns raised by the initial judicial audit.

Whether the recommended fine (P50,000.00 to be deducted from retirement benefits) is proportionate and justified considering the volume of cases left undecided and the mitigating circumstances, such as this being the judge’s first offense.
How the decision aligns with previous precedents and established sanctions for similar judicial inefficiencies.

Whether the failure to promptly dispose of cases undermines public confidence in the judiciary and runs afoul of constitutional mandates and the Code of Judicial Conduct.
The implications of delayed decision-making on the integrity and performance standards within the judicial system.