A.M. No. MTJ-06-1660. November 30, 2006. SPOUSES TREFIL AND LINA A. UMALE, Complainants, vs. JUDGE NICOLAS V. FADUL, JR., MUNICIPAL TRIAL COURT, PAGSANJAN, LAGUNA, Respondent.
FACTS

Complainants charged respondent Judge Nicolas V. Fadul, Jr. with serious neglect of duty, partiality, and gross ignorance of the law. The complaint stemmed from seven criminal cases for violation of B.P. 22 filed by the complainants. On December 4, 2002, respondent judge issued an order indefinitely suspending the proceedings based on the parties’ joint oral manifestation of a compromise agreement. When the accused’s counsel failed to draft the agreement, complainants filed a Motion for Early Decision on January 15, 2003. Due to respondent’s inaction, they filed a second motion on July 10, 2003, and a Motion for Inhibition on August 27, 2003. None of these motions were resolved as of the filing of the administrative complaint. Complainants alleged the suspension order based on a mere verbal manifestation was irregular and demonstrated bias, further citing an incident where the judge allegedly confronted one complainant in a loud voice. They asserted that the failure to resolve the motions within the 90-day period constituted gross neglect.

ISSUE

Whether respondent Judge Nicolas V. Fadul, Jr. is administratively liable for the charges against him.

RULING

Yes, but only for inefficiency constituting undue delay. The Court found respondent judge guilty of undue delay in resolving the pending motions, a less serious charge under Section 9, Rule 140 of the Rules of Court. The judge admitted the delay but offered explanations, including the high volume of cases across his five salas and the limited availability of the public prosecutor. The Court, however, ruled these reasons unacceptable as they did not absolve him of his duty to decide matters promptly. The Constitution and the law mandate that judges resolve motions within 90 days. If burdened by a heavy caseload or other circumstances, a judge must request a formal extension of time from the Court. Respondent judge failed to do so. His inaction on the motions for early decision and inhibition for an extended period constituted inefficiency. The charges of gross ignorance of the law and partiality were not substantiated. The suspension order was a consequence of the parties’ own manifestation, and complainants did not timely move for its reconsideration. The alleged confrontation, while inappropriate, was not sufficiently proven to establish bias. Considering his lack of prior administrative record and heavy workload, the penalty was mitigated. Respondent Judge Nicolas V. Fadul, Jr. was ADMONISHED with a STERN WARNING that a repetition would be dealt with more severely.