AM 95 95 RTJ; (February, 1996) (Digest)
G.R. No. A.M. No. 95-95-RTJ; February 28, 1996
Nicolas L. Lopez, complainant, vs. Judge Reynaldo M. Alon, Regional Trial Court, (Branch 40), Silay City, Negros Occidental, respondent.
FACTS
Complainant Nicolas L. Lopez, the brother of the victim in Criminal Case No. 2422 for murder, charged respondent Judge Reynaldo M. Alon with willful and unlawful delay in rendering judgment, violating the constitutional mandate. The case was submitted for decision in November 1993, but the judgment of acquittal was rendered only on August 9, 1995, a delay exceeding one and a half years.
Respondent judge attributed the delay to several factors. He cited the granting of several motions for extension to file memoranda by the defense counsel, after which he allegedly lost track of the case. He further explained that a water leak necessitated moving his chamber records to the Office of the Clerk of Court, a situation compounded when he had to share a sala with another judge whose records were also stored there, leading to the misplacement of the case records. He maintained the delay resulted from honest negligence and faulted the complainant for not following up on the case.
ISSUE
Whether respondent Judge Reynaldo M. Alon is administratively liable for undue delay in rendering a decision in violation of Section 15, Article VIII of the Constitution .
RULING
Yes, respondent judge is administratively liable. The Constitution mandates that lower courts decide cases within three months from submission. Non-observance is a ground for administrative sanction. While extensions may be granted for meritorious reasons involving complex issues, this requires a proper application from the judge, which was not done here.
The Court rejected the judge’s justifications. The alleged chaotic state of his chamber and the complainant’s failure to follow up the case do not excuse the delay. It is the judge’s non-delegable duty to manage his docket and decide cases promptly and in an organized manner within the reglementary period. The delay unjustly prolonged the suffering of the accused, whose liberty was at stake, and caused the victim’s family excruciating pain, eroding public trust in the judiciary. The judge was fined Ten Thousand Pesos (P10,000.00) with a stern warning.