Title
Ambalong vs. Lubguban
Case
A.M. No. MTJ-02-1449
Decision Date
Feb 5, 2003
Judge delayed decision by 7 months, citing workload; fined P5,000 for gross inefficiency, violating constitutional mandate for timely case resolution.
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Case Summary (A.M. No. MTJ-02-1449)

Case Background

  • Parties Involved: Engr. Fundador Ambalong (complainant) vs. Judge Antonio C. Lubguban (respondent).
  • Nature of Complaint: Delay in resolving Civil Case No. 311 for damages.
  • Court: Metropolitan Circuit Trial Court, Siquijor-Enrique Villanueva-Larena.

Allegations

  • Complainant alleged that Judge Lubguban failed to render a decision in a civil case within the mandated three-month period after it was submitted for decision.
  • The case was submitted for decision on January 5, 2000, after which no decision was rendered until November 27, 2000.
  • The complainant noted that the judge issued a decision in a related criminal case on February 21, 2001, indicating potential bias or negligence.

Judge's Response

  • Judge Lubguban admitted to the delay but claimed he had completed the draft decision before the three-month deadline and intended to finalize it.
  • The judge cited a crowded docket and responsibilities in another sala as reasons for the delay in issuing the decision.

Findings of the Office of the Court Administrator (OCA)

  • Gross Inefficiency: The OCA found Judge Lubguban guilty of gross inefficiency due to the delay in rendering a decision beyond the three-month period as prescribed by the law.
  • Management Responsibilities: The judge's failure to manage his docket effectively was highlighted as a significant factor contributing to the delay.

Legal Principles and Provisions

  • Constitutional Mandate: According to Article VIII, Section 15 of the 1987 Constitution, all lower court cases must be resolved within three months from submission.
  • Judicial Conduct: Canon 3, Rules 3.08 and 3.09 of the Code of Judicial Conduct requires judges to ensure timely resolution of cases and maintain proper court management.

Penalties and Consequences

  • Recommended Sanction: The OCA recommended that Judge Lubguban be fined P5,000.00 for his gross inefficiency.
  • Final Decision: The court agreed with the OCA's recommendation, imposing a fine of P5,000.00 on the respondent judge.

Key Details

• Complainant filed for damages on January 5, 2000. • Decision was due by April 5, 2000, but was rendered only on November 27, 2000. • The delay amounted to seven months beyond the legal deadline. • Judge's justification of a crowded docket was deemed insufficient. • Failure to seek an extension of time...continue reading


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