Case Summary (A.M. No. MTJ-12-1806)
Audit Findings and Allegations
Upon conducting the judicial audit on September 21, 2010, it was revealed that Judge Bustamante had 35 cases pending for decision, of which 21 had exceeded the 90-day reglementary period. Additionally, there were 23 cases with unresolved incidents, 19 of which were also beyond the prescribed timeline. In a Memorandum dated October 6, 2010, DCA Villanueva directed Judge Bustamante to explain his delay in deciding these cases and to act with dispatch in resolving them, producing required documentation before his retirement.
Judge Bustamante’s Responses
In a letter dated November 8, 2010, Judge Bustamante asserted that he had adequately decided most cases before his retirement. He cited challenges such as workload and the requirement to retake testimonies for two specific cases that he claimed were not adequately recorded. His explanations included the assertion that the volume of work, coupled with pressing motions and trials, hindered his ability to meet deadlines.
OCA Recommendations and Findings
The OCA reported that Judge Bustamante had resolved 33 out of the 35 cases, albeit 20 of these were decided beyond the reglementary period—some by up to four years. Furthermore, only six out of the 23 cases with pending incidents had been resolved, all overdue. The OCA concluded that Judge Bustamante was inefficient and recommended a fine of P20,000. In its report dated March 24, 2011, the OCA noted the lack of substantial justification for Bustamante’s delays.
Judicial Responsibility and Timeliness
The court reiterated that timely decision-making is a fundamental obligation of judges, governed by the Constitution and the Code of Judicial Conduct, which mandates decisions be rendered within 90 days from submission. The Supreme Court has consistently underscored that failure to decide cases within the required period constitutes gross inefficiency, warranting administrative sanctions.
Assessment of Explanations for Delays
The Court found Judge Bustamante's explanations unconvincing, especially regarding his failure to decide cases due to the absence of transcripts. The court noted that lack of a transcript cannot justify delay unless the judge was not the presiding officer during the trial. Even in cases where a prior judge presided, Judge Bustamante had an obligation to ensure the transcripts were completed in a timely manner.
Administrative Consequences
The Court highlighted that Judge Bustamante’s failure to seek extensions for deciding cases also contributed to his administrative li
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Background of the Case
- This administrative matter arose from a judicial audit of the Municipal Trial Court in Cities (MTCC) of Alaminos City, Pangasinan, presided over by Judge Borromeo R. Bustamante.
- Judge Bustamante retired on November 6, 2010, prompting an audit conducted by a team from the Office of the Court Administrator (OCA) on September 21, 2010.
Initial Findings of the Audit
- On October 6, 2010, Deputy Court Administrator Raul Bautista Villanueva informed Judge Bustamante that:
- There were 35 cases awaiting decision, with 21 beyond the reglementary period.
- There were 23 cases with pending incidents, with 19 also beyond the reglementary period.
Directives from the OCA
- Judge Bustamante was instructed to:
- Provide a written explanation within 15 days for his failure to decide on specific cases within the reglementary period.
- Decide the cases promptly and submit copies of the decisions post-retirement.
Judge Bustamante's Response
- In a letter dated November 8, 2010, Judge Bustamante claimed:
- He had decided all but two cases before his retirement.
- The two undecided cases required retaking testimonies due to lack of Transcript of Stenographic Notes (TSN).
- His delay was attributed to the high volume of work and urgent matters that required immediate attention.
Detailed Account of the Cases
- Bustamante addressed the pending incidents, stating:
- He resolved several civil and criminal cases but left some motions unresolved due to the need f