The Supreme Court, in A.M. No. 99-7-250-RTC, addressed the administrative liability of a judge who failed to decide cases within the mandated timeframe, even when parties had not submitted their memoranda. The Court emphasized that judges must resolve cases promptly, and the non-submission of memoranda does not excuse delays. This ruling reinforces the judiciary’s commitment to timely justice and upholds the public’s right to a speedy resolution of their cases, ensuring that justice is not unduly delayed.

Justice Delayed: When Awaiting Memoranda Becomes a Breach of Judicial Duty

This case originated from concerns regarding the delayed resolution of several cases in the Regional Trial Court of Manila, Branch 53, presided over by Judge Maximo A. Savellano, Jr. Before his compulsory retirement, questions arose about cases not decided within the reglementary period. A report by the Clerk of Court revealed inconsistencies in the reporting of cases and delays attributed to the non-submission of memoranda by involved parties. This prompted an inquiry into Judge Savellano’s compliance with judicial standards and administrative circulars.

The central issue revolves around whether a judge can be held administratively liable for failing to decide cases within the prescribed period, citing the parties’ failure to submit their respective memoranda as justification. Judge Savellano argued that the cases were not yet submitted for decision because the parties had not filed their memoranda, which he deemed essential for a comprehensive understanding of the issues. However, the Supreme Court scrutinized this justification in light of existing administrative guidelines and the judge’s duty to ensure the prompt disposition of cases.

The Supreme Court turned to Administrative Circular No. 28, dated July 3, 1989, which provides clear guidelines on the submission of memoranda. This circular clarifies that memoranda are not mandatory unless the court specifically requires or allows their filing. More importantly, it states that a case is considered submitted for decision upon the admission of evidence at the trial’s termination, regardless of whether memoranda are filed. Moreover, the circular explicitly states that the 90-day period for deciding a case is not interrupted even if the court grants extensions for filing memoranda. Thus:

“1) As a general rule, the submission of memoranda is not mandatory or required as a matter of course but shall be left to the sound discretion of the court. A memo may not be filed unless require or allowed by the court. X X X.

3) A case is considered submitted for decision upon the admission of the evidence of the parties at the termination of the trial. The ninety (90) day period for deciding the case shall commence to run from submission of the case for decision without memoranda; In case the Court requires or allows its filing, the case shall be considered submitted for decision upon the filing of the last memorandum or the expiration of the period to do so, whichever is earlier X X X.

4) The court may grant extension of time to file memoranda, but the ninety (90) day period for deciding the case shall not be interrupted thereby.

Based on these guidelines, the Court found Judge Savellano’s explanation unpersuasive and insufficient to absolve him from administrative liability. The Court emphasized that judges should decide cases even if parties fail to submit memoranda within the given periods. The Supreme Court highlighted that the non-submission of memoranda does not halt the period for decision and is considered a waiver of the privilege to submit such documents. The Court, in effect, underscored the judiciary’s firm stance on the timely administration of justice.

The Supreme Court further cited Rule 3.05 of Canon 3 of the Code of Judicial Conduct, which mandates judges to dispose of court business promptly and decide cases within the periods fixed by law. Prolonged delays in resolving cases erode public trust in the judiciary, diminish its standards, and bring it into disrepute. As the Court has stated previously:

For delay in the disposition of cases erodes faith and confidence of our people in the judiciary, lowers its standards and brings it into disrepute.^[15]

The Court also addressed Judge Savellano’s argument that his concurrent role as Executive Judge and judge of a Special Criminal Court hindered his ability to decide cases promptly. The Supreme Court acknowledged his dual responsibilities but reiterated that such designation does not excuse compliance with the constitutional duty to decide cases within ninety days from submission. The Court, in effect, emphasized the importance of efficient case management and time management for judges with multiple responsibilities. Judges burdened by heavy caseloads have the option to request additional time from the Supreme Court to decide cases, but the failure to request and secure such extensions constitutes a violation of judicial duties.

The Supreme Court ultimately found Judge Maximo A. Savellano, Jr., liable for undue delay in rendering judgment and for violating Supreme Court Administrative Circular No. 28 and Canon 3, Rule 3.05 of the Code of Judicial Conduct. He was fined P5,000.00, which was deducted from his retirement benefits. This decision serves as a reminder to all judges of their duty to decide cases promptly, regardless of the submission of memoranda by the parties involved. It reinforces the importance of efficient case management and adherence to the prescribed timelines for judicial decision-making.

FAQs

What was the key issue in this case?	The key issue was whether a judge could be held administratively liable for failing to decide cases within the prescribed period, citing the non-submission of memoranda by the parties as justification.
What is the reglementary period for deciding a case?	The reglementary period for deciding a case is three months from the filing of the last pleading, brief, or memorandum, as provided by the Constitution and the Code of Judicial Conduct.
Is the submission of memoranda mandatory for a case to be considered submitted for decision?	No, the submission of memoranda is not mandatory unless the court specifically requires or allows it. A case is considered submitted for decision upon the admission of evidence at the termination of the trial.
Can a judge be excused from deciding a case within the reglementary period if the parties fail to submit their memoranda?	No, a judge cannot be excused. The non-submission of memoranda does not interrupt the period for decision and is considered a waiver of the privilege to submit such documents.
What is the effect of delaying the disposition of cases?	Delaying the disposition of cases erodes public trust in the judiciary, diminishes its standards, and brings it into disrepute.
What should a judge do if they are burdened by a heavy caseload?	Judges burdened by heavy caseloads may request additional time from the Supreme Court to decide cases within the reglementary period.
What administrative circular governs the submission of memoranda?	Administrative Circular No. 28, dated July 3, 1989, governs the submission of memoranda and provides guidelines on when a case is considered submitted for decision.
What Canon of the Code of Judicial Conduct is relevant to this case?	Rule 3.05 of Canon 3 of the Code of Judicial Conduct mandates judges to dispose of court business promptly and decide cases within the periods fixed by law.

In conclusion, this case highlights the judiciary’s commitment to timely justice and the importance of judges adhering to prescribed timelines for decision-making. The ruling clarifies that the non-submission of memoranda does not excuse delays in resolving cases, reinforcing the judiciary’s firm stance on efficient case management and the prompt administration of justice.

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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: CASES SUBMITTED FOR DECISION BEFORE RETIRED JUDGE MAXIMO A. SAVELLANO, JR. RTC- BRANCH 53, MANILA., A.M. No. 99-7-250-RTC, April 05, 2000