AM 06 3 196 RTC; (December, 2008) (Digest)
G.R. No. A.M. No. 06-3-196-RTC / A.M. No. 06-7-416-RTC December 24, 2008
LETTER OF JUDGE JOSEFINA D. FARRALES, ACTING PRESIDING JUDGE, RTC, BR. 72, OLONGAPO CITY RE: 30 CASES AND 84 MOTIONS SUBMITTED FOR DECISION/ RESOLUTION IN THE SAID COURT; AUDIT REPORT ON THE JUDICIAL AUDIT CONDUCTED AT THE REGIONAL TRIAL COURT (RTC), BR. 72, OLONGAPO CITY.
FACTS
This is a consolidation of two administrative matters concerning the Regional Trial Court (RTC), Branch 72, Olongapo City. In A.M. No. 06-3-196-RTC, Judge Josefina D. Farrales, upon her designation as acting presiding judge, reported 30 cases and 84 motions submitted for decision/resolution, many of which were already beyond the reglementary period. She requested an extension to resolve them. The Court directed her to resolve the cases/motions within six months and required Judge Eliodoro G. Ubiadas (the regular judge who was preventively suspended) and Judge Ramon S. Caguioa (a previous acting judge) to explain their failure to decide/resolve within the reglementary periods. Judge Farrales eventually decided/resolved all pending cases and motions.
In A.M. No. 06-7-416-RTC, a judicial audit was conducted from May 17-26, 2006, due to Judge Ubiadas’s indefinite suspension and forthcoming compulsory retirement. The audit revealed a total caseload of 1,114 cases. Apart from the cases/motions in the first matter, the audit found numerous other cases submitted for decision/resolution not acted upon for a considerable time, lapses in records management, and issues concerning the archiving of cases and unexecuted judgments on bonds. The audit also noted that Judge Ubiadas had granted reductions in the liability of bondsmen in several cases. The Court issued resolutions requiring explanations from Judge Ubiadas and Branch Clerk of Court Gerry R. Gruspe regarding these failures and irregularities.
ISSUE
The primary issues are whether Judge Eliodoro G. Ubiadas and Branch Clerk of Court Gerry R. Gruspe are administratively liable for gross inefficiency, gross misconduct, and violations of Supreme Court circulars based on the findings of the judicial audit and the failure to decide/resolve cases and motions within the reglementary period.
RULING
The Supreme Court adopted the findings and recommendations of the Office of the Court Administrator (OCA) with modifications.
1. Judge Eliodoro G. Ubiadas was found GUILTY of Gross Inefficiency and Gross Misconduct. The Court found that Judge Ubiadas failed to decide/resolve numerous cases and motions within the reglementary period, violating the Constitution and the Code of Judicial Conduct. His claim of heavy caseload was rejected as not a valid excuse. Furthermore, he was found guilty of Gross Misconduct for granting reductions in bondsmen’s liability without legal basis and in violation of Supreme Court Circular No. 13-93, which requires prior referral to the Office of the Court Administrator for recommendation. The Court considered his previous administrative sanctions. He was FINED in the amount equivalent to his salary for six (6) months, to be deducted from his retirement benefits.
2. Judge Ramon S. Caguioa was ADMONISHED. The Court accepted his explanation that he was unaware of the unresolved cases/motions during his designation as acting judge due to the heavy inherited docket and lack of attention brought to them. He was admonished to be more circumspect in the performance of his duties.
3. Branch Clerk of Court Atty. Gerry R. Gruspe was found GUILTY of Gross Inefficiency. He failed to ensure the timely submission of monthly reports of cases and to execute judgments on bonds. He was FINED in the amount of Two Thousand Pesos (P2,000.00) with a stern warning.
4. Clerks-in-Charge Catalina A. Atienza and Rizanilla R. Vito were DIRECTED to submit a quarterly report until the updating of the docket books is completed, with a stern warning.
5. The Documentation Division-Legal OCA was DIRECTED to collect from Pacific Union Insurance Company Incorporated its liability for forfeited bonds and to submit a report and recommendation on guidelines for the reduction of bondsmen’s liability within sixty (60) days.
The Court emphasized the mandatory nature of the period for deciding cases and the duty of court personnel to ensure the efficient administration of justice.
