Case Summary (A.M. No. RTJ-10-2220)
Delay in Judicial Proceedings
Angelia alleged that after numerous postponements, a pre-trial for Civil Case No. 54-2001 was finally set for December 6, 2007. However, on December 20, 2007, he received an order dismissing the case for failure to prosecute. Subsequently, he filed a motion for reconsideration on December 28, 2007, maintaining that the delay was not attributable to him. After further inaction, he filed an urgent motion on July 28, 2008, seeking early resolution of his motion for reconsideration.
Response from Judge Grageda
In response to the allegations, Judge Grageda provided a comment dated February 12, 2009, where he attributed the delay to the numerous resettings of hearings and the repeated absences of the parties involved. He acknowledged the backlog of around 800 cases he managed and admitted to the apparent failure to resolve the motion timely. He expressed his intention to improve and apologized for the delay, particularly as he was the only acting RTC judge in a district covering two cities and three municipalities.
Findings by the Office of the Court Administrator
The Office of the Court Administrator (OCA) subsequently recommended that Judge Grageda be fined ₱5,000.00 for his failure to comply with judicial timelines. The recommendation was substantively supported by arguments referencing the Constitution's mandate for timely resolutions, specifically that lower courts must resolve cases within three months from submission. Relevant sections of the Code of Judicial Conduct emphasize that judges must administer justice impartially and without delay, further underscoring the standards expected of judicial officials.
Judicial Guidelines and Accountability
The Supreme Court has established guidelines concerning the prompt disposition of judicial business, mandating compliance from lower court judges. Specifically, these guidelines assert the need for timely resolution of cases and outline repercussions for delays, which constitute gross inefficiency and warrant administrative sanctions. Judge Grageda's admission of fault regarding the delay in resolving Angelia's motion was acknowledged,
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Case Background
- Complainant: Pio Angelia, who filed a verified Complaint on November 7, 2008.
- Respondent: Judge Jesus L. Grageda of the Regional Trial Court, Branch 4, Panabo City.
- Nature of Complaint: Delay in the resolution of motions related to Civil Case No. 54-2001, titled Pio Angelia v. Arnold Oghayan.
Timeline of Events
- August 8, 2001: Civil Case No. 54-2001 was filed.
- December 6, 2007: A pre-trial was finally set after multiple postponements.
- December 20, 2007: An order dismissing the case for failure to prosecute was received by Angelia's counsel.
- December 28, 2007: Angelia filed a motion for reconsideration, asserting that the failure to prosecute was not his fault.
- July 28, 2008: Angelia submitted an Urgent Motion for Early Resolution of the December 2007 Motion for Reconsideration.
- February 12, 2009: Judge Grageda submitted his Comment regarding the delay.
Judge Grageda's Response and Explanation
- Judge Grageda attributed the delay to:
- Numerous resettings and the repeated absences of the parties involved.
- A significant workload of approximately 800 cases in his sala.
- Acknowledged that the d