OFFICE OF THE COURT ADMINISTRATOR vs. JUDGE BORROMEO R. BUSTAMANTE, MUNICIPAL
TRIAL COURT IN CITIES, ALAMINOS CITY, PANGASINAN, A.M. No. MTJ-12-1806, (Formerly
A.M. No. 11-4-36-MTCC), April 7, 2014
“x x x.
Decision-making, among other duties, is the primordial
and most important duty of a member of the bench. The speedy disposition of
cases in the courts is a primary aim of the judiciary so the ends of justice
may not be compromised and the judiciary will be true to its commitment to
provide litigants their constitutional right to a speedy trial and a speedy
disposition of their cases.8
The Constitution, Code of Judicial Conduct, and
jurisprudence consistently mandate that a judge must decide cases within 90
days from submission. As the Court summed up in Re: Report on the Judicial
Audit Conducted in the RTC, Br. 4, Dolores, Eastern Samar9:
Section 15, Article VIII of the
Constitution states that judges must decide all cases within three months from
the date of submission. In Re: Report on the Judicial Audit Conducted at the
Municipal Trial Court in Cities (Branch 1), Surigao City, the Court held that:
A judge is mandated to render a
decision not more than 90 days from the time a case is submitted for decision.
Judges are to dispose of the court’s business promptly and decide cases within
the period specified in the Constitution, that is, 3 months from the filing of
the last pleading, brief or memorandum. Failure to observe said rule
constitutes a ground for administrative sanction against the defaulting judge,
absent sufficient justification for his non-compliance therewith.
Rule 1.02, Canon 1 of the Code of
Judicial Conduct states that judges should administer justice without delay.
Rule 3.05 of Canon 3 states that judges shall dispose of the court's business
promptly and decide cases within the required periods. In Office of the Court
Administrator v. Javellana, the Court held that:
A judge cannot choose his deadline
for deciding cases pending before him. Without an extension granted by this
Court, the failure to decide even a single case within the required period
constitutes gross inefficiency that merits administrative sanction.
The Code of Judicial Conduct,
specifically Canon 3, Rule 3.05 mandates judges to attend promptly to the
business of the court and decide cases within the periods prescribed by law and
the Rules. Under the 1987 Constitution, lower court judges are also mandated to
decide cases within 90 days from submission.
Judges must closely adhere to the
Code of Judicial Conduct in order to preserve the integrity, competence and
independence of the judiciary and make the administration of justice more
efficient. Time and again, we have stressed the need to strictly observe this
duty so as not to negate our efforts to minimize, if not totally eradicate, the
twin problems of congestion and delay that have long plagued our courts.
In Office of the Court
Administrator v. Garcia-Blanco, the Court held that the 90-day reglementary
period is mandatory. Failure to decide cases within the reglementary period
constitutes a ground for administrative liability except when there are valid
reasons for the delay. (Citation omitted.)
This Court has always emphasized the need for judges
to decide cases within the constitutionally prescribed 90-day period. Any delay
in the administration of justice, no matter how brief, deprives the litigant of
his right to a speedy disposition of his case. Not only does it magnify the
cost of seeking justice, it undermines the people’s faith and confidence in the
judiciary, lowers its standards, and brings it to disrepute.10
A member of the bench cannot pay mere lip service to
the 90-day requirement; he/she should instead persevere in its
implementation.11 Heavy caseload and demanding workload are not valid reasons
to fall behind the mandatory period for disposition of cases.12 The Court
usually allows reasonable extensions of time to decide cases in view of the
heavy caseload of the trial courts. If a judge is unable to comply with the
90-day reglementary period for deciding cases or matters, he/she can, for good
reasons, ask for an extension and such request is generally granted.13 But
Judge Bustamante did not ask for an extension in any of these cases. Having
failed to decide a case within the required period, without any order of
extension granted by the Court, Judge Bustamante is liable for undue delay that
merits administrative sanction.
x x x,"
