Title
Supreme Court
Re: Judicial Audit Conducted in the RTC Branch 73, Antipolo City
Case
A.M. No. 05-2-113-RTC
Decision Date
Dec 7, 2005
Judge Rivera found guilty of undue delay in deciding 200+ cases due to heavy caseload and lack of stenographers; fined P10,000, mitigated by compliance efforts.

Case Summary (A.M. No. 05-2-113-RTC)

Case Facts

The audit revealed that at the time it was conducted, Branch 73 had a total of 909 pending cases, of which 235 cases were already submitted for decision. Notably, 200 of these cases were found to be beyond the reglementary period for resolution. Additionally, the audit uncovered unresolved incidents in 32 cases and 58 cases that were dormant, with no actions taken despite significant time lapsing. Judge Rivera acknowledged these findings and pledged to act swiftly on the pending cases.

Court Administrators' Directives

In response to the audit findings, a memorandum dated March 1, 2004, directed Judge Rivera to explain his failure to decide on the pending cases within the required period and to submit the status of specific cases. In April 2004, Judge Rivera provided explanations and asserted that he had resolved the aforementioned cases, including submitting the necessary documentation.

Factors Contributing to Delay

Judge Rivera attributed the delays in case resolution to several factors including an overwhelming case load of 1,293 cases, a shortage of stenographers (with one on maternity leave), and the necessity for daily hearings. Despite these challenges, he claimed efforts to comply with the Office of Court Administrator’s (OCA) requirements and to address his backlog of cases.

Findings of the OCA

The evaluation conducted by the OCA concluded that Judge Rivera had incurred unreasonable delays that constituted administrative liability. While noting that his heavy case load and inadequate resources mitigated his culpability, the report criticized his failure to seek extensions of time as required by the rules.

Duration and Impact of Delays

The Court underscored the essential principle of expediency in judicial proceedings, asserting that delays can erode public confidence in the judicial system. As part of this, the Court cited previous rulings affirming a judge's duty to resolve cases within mandated timeframes, underscoring the implications of undue delay which hampers justice.

Administrative Liability and Decision

While acknowledging Judge Rivera’s heavy case load and efforts to finalize pending cases before his retirement, the Court found him administratively liable for undue delay in decisio

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