Facts:

The case involves Judge Virgilio D. Quijano, who presided over the Regional Trial Court (RTC) of Manila, Branch 20. The administrative matter arose from the non-resolution of several civil cases within the mandated 90-day reglementary period and the failure to act on other cases for an extended duration. On November 22, 1999, a Judicial Audit Team from the Office of the Court Administrator (OCA) conducted an inventory and audit of cases in RTC-Manila, Branch 20. The audit report, dated January 6, 2000, revealed that Judge Quijano had failed to resolve eight civil cases within the required timeframe. These cases included Civil Case No. 95-73415 (Praxedes F. Pasicolan and Carlos P. Garcia vs. Angelina de Chavez), Civil Case No. 94-70306 (BPI Savings Bank vs. Changes Garments Mfg., Inc. et al.), and several others, with submission dates ranging from January 1997 to August 1999. The audit also indicated that Judge Quijano had not acted on eight additional civil cases for a consid...

Facts:

1. Judicial Audit Conducted: On 22 November 1999, a Judicial Audit Team from the Office of the Court Administrator (OCA) conducted an audit of cases in RTC-Manila, Branch 20, presided over by Judge Virgilio D. Quijano.
2. Findings of the Audit: The audit revealed that Judge Quijano failed to resolve eight (8) civil cases within the 90-day reglementary period. These cases included:
   • Civil Case No. 95-73415 (Unlawful Detainer) – submitted for decision on 7 January 1997.
   • Civil Case No. 94-70306 (Replevin and Damages) – submitted for resolution on 21 August 1998.
   • Civil Case No. 89-51404 (Declaration of Nullity of OCT's) – submitted for resolution on 25 September 1998.
   • Civil Case No. 93-68481 (Damages) – submitted for resolution on 17 May 1999.
   • Civil Case No. 93-66416 (Damages) – submitted for decision on 20 May 1999.
   • Civil Case No. 98-89167 (Delivery of Personal Property) – submitted for resolution on 9 June 1999.
   • Civil Case No. 98-90244 (Sum of Money) – submitted for resolution on 28 July 1999.
   • Civil Case No. 98-87354 (Replevin and Damages) – submitted for resolution on 10 August 1999.
3. Failure to Act on Other Cases: The audit also revealed that Judge Quijano failed to act on eight (8) other civil cases for a considerable length of time.
4. Supreme Court Resolution: On 8 March 2000, the Supreme Court required Judge Quijano to explain his failure to resolve the cases within the prescribed period and ordered the retention of P20,000.00 from his retirement benefits to answer for any administrative liability.
5. Judge Quijano’s Explanation: On 5 May 2000, Judge Quijano submitted a two-page explanation, claiming that any delays were not intentional but due to inadvertence or oversight.

Issue:

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Ruling:

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Ratio:

1. Constitutional and Legal Mandate: The Constitution mandates that all cases or matters filed before lower courts must be decided or resolved within three (3) months from the date of submission. Rule 3.05 of Canon 3 of the Code of Judicial Conduct also requires judges to dispose of court business promptly and decide cases within the periods fixed by law.
2. Gross Inefficiency: Failure to decide cases within the required period constitutes gross inefficiency, which is a ground for administrative sanction. Judges are repeatedly reminded of this duty, and delays are not excusable.
3. Insufficient Explanation: Judge Quijano’s explanation that the delays were due to inadvertence or oversight was deemed unsatisfactory. He failed to provide valid reasons for the delays and did not submit supporting documents for some cases allegedly resolved within the reglementary period.
4. Judicial Responsibility: Judges play a crucial role in the administration of justice and must ensure the prompt disposition of cases. They are duty-bound to act vigilantly and conscientiously in fulfilling their responsibilities.
5. Remedy for Heavy Caseloads: Judges burdened by heavy caseloads may request additional time from the Supreme Court to resolve cases, especially when complex legal issues are involved.