The Supreme Court ruled that Judge Jesus V. Quitain of the Regional Trial Court (RTC) of Davao City (Branch 15) was guilty of undue delay in resolving a motion for reconsideration regarding a motion for inhibition. This decision underscores the judiciary’s commitment to timely justice and the consequences for failing to act promptly on pending matters. The Court emphasized that judges must resolve cases and motions within the prescribed periods, and any failure to do so without valid justification will result in administrative sanctions to maintain public trust in the judicial system.

Justice Delayed: When a Judge’s Inaction Leads to Administrative Liability

This case arose from a complaint filed by Jose B. Custodio against Judge Jesus V. Quitain, alleging undue delay in resolving incidents related to Criminal Case No. 37921-96, where Custodio was accused of rape. Custodio claimed that Judge Quitain failed to act on his Motion for Reconsideration (MR) of the Order denying his Final Motion for Inhibition for approximately one year and seven months. The central legal question was whether Judge Quitain’s delay in resolving the MR constituted an administrative offense warranting disciplinary action.

The Office of the Court Administrator (OCA) investigated the matter and found that while Judge Quitain had initially denied Custodio’s Final Motion for Inhibition, he failed to resolve the subsequent Motion for Reconsideration despite issuing orders declaring it submitted for decision. The Court of Appeals (CA), in a related Petition for Mandamus filed by Custodio, also noted the unreasonable delay, stating that the MR had been pending resolution for an extended period in violation of procedural rules. The Supreme Court agreed with the OCA’s finding of undue delay, emphasizing that judges are expected to dispose of court business promptly and decide cases within the required periods. Promptness in resolving pending matters is crucial to maintaining public trust in the judiciary.

The Court highlighted the importance of timely resolution of motions and interlocutory matters, noting that delay can disrupt the course of trials and infringe upon the parties’ right to a speedy disposition of their case. While the OCA and the CA cited Section 4 of Rule 37 of the Rules of Court regarding the resolution of motions for new trial or reconsideration, the Supreme Court clarified that this specific rule does not apply to motions for reconsideration of orders denying inhibition, as such orders are interlocutory and not final judgments. However, the Court emphasized that all presiding judges must endeavor to act promptly on all motions and interlocutory matters within the 90-day period provided in the Constitution.

According to the Court, this constitutional mandate ensures that the judicial process remains efficient and effective. The Court pointed out the relevant provision in the Constitution:

“SEC. 15. (1) All cases or matters filed after the effectivity of this Constitution must be decided or resolved within twenty-four months from date of submission for the Supreme Court, and, unless reduced by the Supreme Court, twelve months for all lower collegiate courts, and three months for all other lower courts.”

Undue delay in rendering a decision or order is classified as a less serious charge under Rule 140 of the Rules of Court. The penalty for such an offense includes suspension without pay for one to three months, or a fine ranging from P10,000 to P20,000. The Court determined that Judge Quitain’s actions warranted a fine of P10,100, coupled with a warning that similar conduct in the future would be met with more severe sanctions. This decision underscores the Court’s commitment to enforcing judicial efficiency and accountability, ensuring that judges fulfill their duty to administer justice without undue delay. Moreover, the Court found that the immediate resolution of the pending Motion in Criminal Case No. 37921-96 was essential to the continuation of the trial of the case.

The Court’s ruling reinforces the principle that while specific rules may not always prescribe exact timelines for resolving every type of motion, the overarching duty of judges is to act promptly. The absence of a specific rule does not excuse undue delay, particularly when such delay impedes the progress of a case and undermines the parties’ right to a speedy resolution. The imposition of a fine serves as a deterrent, reminding judges of their responsibility to prioritize the efficient administration of justice. By penalizing undue delay, the Court seeks to uphold the integrity of the judiciary and maintain public confidence in the legal system.

FAQs

What was the key issue in this case?	The key issue was whether Judge Quitain’s delay in resolving the Motion for Reconsideration constituted an administrative offense warranting disciplinary action. The Supreme Court examined the judge’s failure to act promptly on a pending motion.
What did the Court ultimately decide?	The Court found Judge Quitain guilty of undue delay in resolving a motion. He was fined P10,100 and warned that future similar actions would be dealt with more severely.
What rule did the Court say was not applicable to this case?	The Court clarified that Section 4 of Rule 37 of the Rules of Court, which pertains to motions for new trial or reconsideration of a final judgment, was not applicable. This is because the motion in question concerned an interlocutory order denying inhibition, not a final judgment.
What is the general time frame judges should adhere to?	Judges must endeavor to act promptly on all motions and interlocutory matters pending before their courts within the 90-day period provided in the Constitution. This ensures timely justice.
What is considered a less serious charge under Rule 140?	Under Rule 140 of the Rules of Court, undue delay in rendering a decision or an order is considered a less serious charge. It warrants penalties such as suspension or a fine.
What was the significance of the Court of Appeals’ involvement?	The Court of Appeals granted Custodio’s Petition for Mandamus, compelling Judge Quitain to act on the pending Motion for Reconsideration. The CA’s findings supported the claim of undue delay.
Why is it important for judges to act promptly on motions?	Prompt resolution of motions is crucial for maintaining public trust in the judiciary, ensuring a speedy disposition of cases, and upholding the integrity of the legal system. Delay can undermine public confidence.
What should judges do if they cannot resolve matters within the required periods?	If judges cannot resolve pending cases, motions, or other incidents within the reglementary period, they should file a request for extension with the Supreme Court. This is essential to avoid administrative sanctions.

The Supreme Court’s decision in this case serves as a critical reminder to all members of the judiciary about the importance of adhering to timelines and promptly addressing pending matters. By holding judges accountable for undue delays, the Court reinforces its commitment to ensuring fair, efficient, and timely justice for all.

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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: Jose B. Custodio vs. Judge Jesus V. Quitain, A.M. No. RTJ-03-1761, April 30, 2003