Case Summary (G.R. No. 179018)
The Case and the Facts
On July 31, 1998, Judge Masamayor requested an extension of time from the Court Administrator to decide Civil Case No. 0020, which was expected by July 14, 1998, and Criminal Case No. 98-384, due by June 2, 1998. Following her request, she managed to issue a decision for Criminal Case No. 98-384 on August 6, 1998, and later sought an additional thirty days for Civil Case No. 0020, which she resolved by August 27, 1998. Subsequently, a January 19, 1999 directive from the Court required her to explain why her extension requests were made post-deadline.
Judge Masamayor's Explanations
In her March 1, 1999 letter, Judge Masamayor explained that her omission in failing to mention a prior extension request stemmed from inadvertence rather than intent. She acknowledged her procedural missteps and pledged to be more diligent in the future. However, the Court found her explanations unsatisfactory, especially in relation to the timing of her extension requests.
Findings by the Office of the Court Administrator
The Office of the Court Administrator (OCA), in its July 23, 1999 report, noted recurring issues with Judge Masamayor's adherence to the 90-day decision-making period mandated for judges. She had been fined previously for similar violations, and consequently, the OCA recommended a fine of P15,000 accompanied by a stern warning regarding future infractions.
The Court's Ruling
The Court concurred with the OCA's recommendation but adjusted the fine to P10,000. It reiterated the importance of judges deciding cases promptly and highlighted that repeated lapses in this regard reflect gross inefficiency. The admonishment reiterated the roles and duties of judges, emphasizing that even an increasing caseload does not excuse delays in the resolution of cases.
Conclusion
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Case Overview
- Judge Irma Zita V. Masamayor of the Regional Trial Court (RTC) in Talibon, Bohol, requested extensions of time to decide two cases: Civil Case No. 0020 and Criminal Case No. 98-384.
- The deadline for Civil Case No. 0020 was July 14, 1998, and for Criminal Case No. 98-384, it was June 2, 1998.
- Judge Masamayor completed the decision for Criminal Case No. 98-384 on August 6, 1998.
Requests for Extension
- On July 31, 1998, Judge Masamayor sent a letter to the Court Administrator requesting an extension for the aforementioned cases.
- On August 17, 1998, she requested an additional 30 days to resolve a Motion to Dismiss in Civil Case No. 0020, which she resolved on August 27, 1998.
- The Court Administrator sought explanations for the timing and nature of her extension requests after the expiration of the reglementary periods.
Court's Inquiry and Judge's Explanation
- On January 19, 1999, the