A.M. No. MTJ-00-1279. March 1, 2001. JUDGE ALICIA GONZALES-DECANO, complainant, vs. JUDGE ORLANDO ANA F. SIAPNO, respondent.
FACTS

Executive Judge Alicia Gonzales-Decano reported to the Court Administrator that respondent Judge Orlando Ana F. Siapno of the Urdaneta Municipal Trial Court failed to decide or resolve seven cases within the mandatory periods. The cases, submitted for decision between June 1996 and February 1997, included civil actions for forcible entry, unlawful detainer, and an election protest, as well as criminal cases. The delays ranged from several months to over a year beyond the 90-day reglementary period.
In his comment, respondent Judge did not deny the delays but offered various explanations. He cited the heavy workload and chronic backlog in the transcription of stenographic notes due to having only one stenographer. For some cases, he claimed to have dictated decisions but they were not typed promptly, while for others, he stated he awaited completed transcripts. He also argued that his additional designations as presiding judge in other municipalities and his preventive suspension in May 1997 contributed to the backlog.

ISSUE

Whether respondent Judge Orlando Ana F. Siapno is administratively liable for gross inefficiency for his failure to decide the seven cases within the reglementary period.

RULING

Yes, respondent Judge is administratively liable. The Supreme Court found his excuses unavailing. The constitutional mandate and the Code of Judicial Conduct (Rule 3.05) require judges to dispose of court business promptly and decide cases within required periods. Failure to do so constitutes gross inefficiency warranting administrative sanction.
The Court systematically rejected the respondent’s justifications. The non-completion of stenographic notes does not excuse the delay; judges are duty-bound to proceed using their own notes and the available records. For cases governed by the Revised Rule on Summary Procedure (like ejectment cases), decisions are required within 30 days after submission, making the delay even more egregious. The claim of additional assignments is likewise not a valid defense, as the proper recourse was to request a reasonable extension of time from the Supreme Court, which is routinely granted. His preventive suspension also did not absolve him for delays that had already accrued prior to the suspension order.
However, the Court considered his previous record of disposing of a significant number of cases in prior years as a mitigating factor. Consequently, the Court adopted the Office of the Court Administrator’s recommendation and imposed a fine of Five Thousand Pesos (P5,000.00) with a stern warning that a repetition would be dealt with more severely.