The Supreme Court in Fajardo v. Natino reiterated the stringent constitutional mandate requiring judges to decide cases promptly. The Court found Judge Natino guilty of undue delay for failing to decide a case within the prescribed 90-day period, despite presented justifications. This ruling underscores the judiciary’s commitment to upholding the right to speedy disposition of cases, a cornerstone of fair and efficient justice, and highlights the importance of judges seeking extensions when facing difficulties in meeting deadlines.

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This case arose from a complaint filed by Daniel G. Fajardo against Judge Antonio M. Natino, alleging violations of the Constitution and the Rules of Court in handling two civil cases. Fajardo specifically accused Judge Natino of delaying the resolution and release of decisions, falsifying certificates of service, failing to resolve a motion for contempt, and improperly entertaining a second motion for reconsideration. Essentially, Fajardo claimed these delays and procedural lapses were part of a scheme by Judge Natino to solicit a bribe from one of the parties involved.

Judge Natino defended himself, citing various factors that contributed to the delay in resolving Civil Case No. 20225. These included the resignation of his stenographer, his duties as Acting and full-fledged Executive Judge, the renovation of the Iloilo City Hall, bomb threats, and frequent power outages. He argued that he prioritized the quality of justice over speed, and that the 90-day rule should only be considered mandatory when delays are vexatious, capricious, or oppressive. He denied falsifying certificates of service and refuted the charges related to Civil Case No. 07-29298 by presenting an order detailing the court’s actions on the pending motions.

After investigation, the Investigating Justice found no merit in most of the charges against Judge Natino, primarily due to Fajardo’s failure to present evidence. However, the Investigating Justice found Judge Natino guilty of undue delay in resolving Civil Case No. 20225 and recommended a fine. The Office of the Court Administrator (OCA) adopted this recommendation. The Supreme Court then reviewed the case to determine whether Judge Natino was indeed guilty of the charges against him.

The Supreme Court agreed with the Investigating Justice and the OCA’s findings, except for the recommended penalty. The Court emphasized that the Constitution mandates lower courts to decide cases within three months, as stated in Article VIII, Section 15(1):

Article VIII, Section 15(1) of the 1987 Constitution provides that lower courts have three months within which to decide cases or resolve matters submitted to them for resolution.

Furthermore, Canon 3, Rule 3.05 of the Code of Judicial Conduct requires judges to dispose of their business promptly and decide cases within the required period. The Court cited Re: Cases Submitted for Decision Before Hon. Baluma, emphasizing the importance of timely justice:

The Court has consistently impressed upon judges the need to decide cases promptly and expeditiously under the time-honored precept that justice delayed is justice denied. Every judge should decide cases with dispatch and should be careful, punctual, and observant in the performance of his functions for delay in the disposition of cases erodes the faith and confidence of our people in the judiciary, lowers its standards and brings it into disrepute. Failure to decide a case within the reglementary period is not excusable and constitutes gross inefficiency warranting the imposition of administrative sanctions on the defaulting judge.

The Court acknowledged Judge Natino’s explanations for the delay but reiterated that the 90-day period is mandatory. While recognizing the heavy caseloads and various challenges faced by trial courts, the Court emphasized that judges should request extensions when they cannot decide a case promptly. Judge Natino’s failure to seek an extension was a critical factor in the Court’s decision.

The Court also pointed out that Article VIII, Section 15 of the Constitution provides judges an avenue to ask for a reasonable extension of time:

Whenever a judge cannot decide a case promptly, all he has to do is to ask the Court for a reasonable extension of time to resolve it.

According to Section 9(1), Rule 140, as amended by Administrative Matter No. 01-8-10-SC, undue delay in rendering a decision is a less serious charge, punishable by suspension or a fine. However, the specific penalty varies depending on the circumstances. Given that this was Judge Natino’s first offense and his long service in the Judiciary, the Court imposed a fine of P10,000, to be deducted from his retirement benefits.

FAQs

What was the key issue in this case?	The key issue was whether Judge Natino was guilty of violating the constitutional mandate to decide cases within the prescribed 90-day period, specifically in relation to Civil Case No. 20225.
What were the charges against Judge Natino?	Judge Natino was charged with violating the Constitution and the Rules of Court, including delaying the resolution and release of decisions, falsifying certificates of service, failing to resolve a motion for contempt, and improperly entertaining a second motion for reconsideration.
What reasons did Judge Natino give for the delay in resolving Civil Case No. 20225?	Judge Natino cited the resignation of his stenographer, his duties as Executive Judge, the renovation of the Iloilo City Hall, bomb threats, and frequent power outages as reasons for the delay.
Did the Supreme Court accept Judge Natino’s reasons as a valid excuse for the delay?	The Supreme Court acknowledged Judge Natino’s reasons but emphasized that the 90-day period is mandatory and that judges should request extensions if they cannot meet the deadline.
What is the constitutional basis for the 90-day period to decide cases?	Article VIII, Section 15(1) of the 1987 Constitution provides that lower courts have three months within which to decide cases or resolve matters submitted to them for resolution.
What penalty was imposed on Judge Natino?	The Supreme Court found Judge Natino guilty of undue delay and imposed a fine of P10,000, to be deducted from his retirement benefits.
What administrative rule governs the penalty for undue delay in rendering a decision?	Section 9(1), Rule 140, as amended by Administrative Matter No. 01-8-10-SC, classifies undue delay as a less serious charge, punishable by suspension or a fine.
Can a judge ask for an extension of time to decide a case?	Yes, the Supreme Court has stated that whenever a judge cannot decide a case promptly, they should request a reasonable extension of time from the Court.
What was the effect of Fajardo failing to appear to the hearings?	Fajardo’s lack of appearance meant that he was not able to present any evidence to prove his allegations. Because of that, the Supreme Court ruled in favor of Judge Natino with all other charges that was filed.

The Supreme Court’s decision in Fajardo v. Natino serves as a reminder to judges of their duty to decide cases promptly and to seek extensions when necessary. This case reinforces the constitutional right of parties to a speedy disposition of their cases and underscores the judiciary’s commitment to ensuring efficient and fair administration of justice.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: DANIEL G. FAJARDO, COMPLAINANT, V. JUDGE ANTONIO M. NATINO, REGIONAL TRIAL COURT, BRANCH 26, ILOILO CITY, RESPONDENT., A.M. No. RTJ-16-2479, December 13, 2017