Case Summary (G.R. No. L-35726)
Background of the Case
The complaint states that after the proceedings in Civil Case No. 311 were terminated on September 13, 1999, the respondent judge instructed both parties to submit their respective memoranda within thirty days from receiving the last transcript. Ambalong submitted his memorandum on January 5, 2000, while the defendants failed to file theirs. However, despite this, as of the time the administrative complaint was filed on March 14, 2001, no decision had been rendered by the respondent.
Allegations of Delay
Ambalong alleged that on February 21, 2001, the respondent issued a decision in a related criminal case, acquitting the accused driver, who was also a defendant in the civil case. Ambalong claimed that the respondent breached the rule which mandates judges to make a decision within three months of the case being submitted for resolution.
Respondent's Explanation
In his Comment, Judge Lubguban acknowledged that the last pleading in the civil case was indeed filed on January 5, 2000, and that he began drafting the decision shortly thereafter. He admitted that he completed the draft before the three-month deadline but kept it in his office for final edits. The delay was attributed to his busy docket and other obligations in another sala of the MCTC in Lazi, Siquijor. Ultimately, he issued the decision on November 27, 2000, but the actual copies were not delivered to the parties until March 6, 2001, due to oversight.
Findings of the Office of the Court Administrator
The Office of the Court Administrator (OCA) evaluated the pleadings and found Judge Lubguban guilty of gross inefficiency, recommending a fine of P5,000. The OCA noted that the respondent admitted he had not decided the case within the mandated three-month period. They emphasized that his explanation of a crowded docket did not justify the unreasonable delay.
Legal Standards and Implications
The 1987 Constitution mandates that cases at the trial level must be resolved within three months from the submission date of the last filing. In this instance, the latest memorandum was submitted on January 5, 2000, giving a deadline of April 5, 2000, to issue a decision. However, the decision was delivered seven months late, constituting gross inefficiency. Th
...continue readingCase Syllabus (G.R. No. L-35726)
Case Background
- The case involves an administrative complaint filed by Engr. Fundador Ambalong against Judge Antonio C. Lubguban, presiding judge at the Metropolitan Circuit Trial Court in Siquijor.
- The complaint centers on the delay in resolving Civil Case No. 311, wherein Ambalong was the plaintiff against defendants Jose Castillon and Rudy Castillon for damages based on quasi-delict.
- Following the termination of proceedings on September 13, 1999, the judge directed both parties to submit memoranda within 30 days from receiving the last transcript.
Timeline of Events
- Complainant submitted his memorandum on January 5, 2000, while the defendants did not submit any memorandum.
- Despite the deadline, the judge did not render a decision on the civil case by the time the administrative complaint was filed on March 14, 2001.
- Notably, on February 21, 2001, the judge issued a decision in a separate criminal case acquitting the accused driver, Jose Castillon, who was also a defendant in the civil case.
Allegations Against the Judge
- The complainant alleged that Judge Lubguban violated the rule requiring judges to decide cases within three months from the sub