TL;DR

In a decisive move against judicial inefficiency, the Supreme Court of the Philippines found Judge Miguel S. Asuncion guilty of Gross Neglect of Duty for an egregious seven-year delay in resolving a motion for preliminary injunction. This ruling underscores the judiciary’s commitment to timely justice and holds judges strictly accountable for delays that undermine public trust and access to justice. Judge Asuncion was fined PHP 201,000.00 and sternly warned against future delays, sending a clear message that prolonged inaction on cases will not be tolerated, especially when it impacts the livelihoods of those seeking urgent judicial relief.

Seven Years of Silence: Judge Sanctioned for Unconscionable Delay in Resolving Injunction Plea

The case of Castillo v. Asuncion throws a stark light on the critical importance of judicial efficiency and the detrimental consequences of prolonged delays in the administration of justice. At the heart of this administrative complaint was Judge Miguel S. Asuncion’s failure to resolve a simple motion for preliminary injunction for an astounding seven years. The complainant, Rolly C. Castillo, representing stallholders at a public market, sought the injunction to prevent their forceful eviction. This inaction prompted Castillo to file a complaint for Gross Inefficiency and Dishonesty against Judge Asuncion, arguing that such extensive delay constituted a dereliction of judicial duty and a denial of timely justice.

The facts reveal a concerning timeline of inaction. After the case, Civil Case No. 15-10803, was assigned to Judge Asuncion’s Regional Trial Court branch, hearings were conducted, and memoranda were submitted by the parties in 2016. Specifically, the plaintiffs submitted their memorandum on July 14, 2016, effectively submitting the motion for resolution. Despite this, Judge Asuncion remained silent. Numerous motions filed by the plaintiffs to expedite the resolution – including multiple ex-parte motions and a motion to re-open hearing – were met with continued silence. It was only after an administrative complaint was lodged against him that Judge Asuncion finally issued an order denying the preliminary injunction on April 11, 2023.

The Supreme Court, in its decision penned by Justice Inting, unequivocally sided with the complainant. The Court emphasized the constitutional mandate for the speedy disposition of cases, citing Article VIII, Section 15 of the 1987 Constitution, which sets a three-month deadline for lower courts to resolve matters after submission. This constitutional provision is further reinforced by Canon 6, Section 5 of the New Code of Judicial Conduct, which mandates judges to perform their duties, including delivering decisions, with “reasonable promptness.” OCA Circular No. 243-2022 further reiterates the importance of adhering to these timelines. The Court quoted the constitutional provision:

SECTION 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.

(2) A case or matter shall be deemed submitted for decision or resolution upon the filing of the last pending, brief, or memorandum required by the Rules of Court or by the court itself.

(3) Upon the expiration of the corresponding period, a certification to this effect signed by the Chief Justice or the presiding judge shall forthwith be issued and a copy thereof attached to the record of the case or matter, and served upon the parties. The certification shall state why a decision or resolution has not been rendered or issued within said period.

(4) Despite the expiration of the applicable mandatory period, the court, without prejudice to such responsibility as may have been incurred in consequence thereof, shall decide or resolve the case or matter submitted thereto for determination, without further delay.

Judge Asuncion’s defense, citing heavy workload and the COVID-19 pandemic, was deemed insufficient. The Court highlighted that the motion for preliminary injunction was submitted for resolution long before the pandemic. The justices stressed that while the Court acknowledges the challenges faced by judges, these challenges cannot excuse a blatant disregard for mandated timelines, especially in cases requiring urgent action like preliminary injunctions. The Court found that the delay was not mere Simple Neglect of Duty, but rose to the level of Gross Neglect of Duty, defined as “characterized by the want of even slight care, or by acting or omitting to act in a situation where there is a duty to act, not inadvertently but [willfully] and intentionally, with a conscious indifference to the consequences.”

In determining the penalty, the Court considered a previous administrative reprimand against Judge Asuncion for undue delay in another case. This prior offense served as an aggravating circumstance, leading to a fine of PHP 201,000.00, exceeding the base fine for Gross Neglect of Duty. The Court, however, did not find sufficient evidence to support the Dishonesty charge related to Judge Asuncion’s certification for salary receipt.

A concurring opinion by Justice Caguioa further clarified the scope of disciplinary actions against judges who are also members of the Bar. Justice Caguioa emphasized that not every administrative offense under Rule 140 automatically warrants disciplinary action as a lawyer. He argued that the misconduct must be of such character that it affects the judge’s qualification as a lawyer or demonstrates moral delinquency. In this case, while Judge Asuncion’s delay was a serious breach of judicial duty, it primarily pertained to his functions as a judge and not to conduct that would independently warrant disbarment. Thus, Justice Caguioa agreed with the ponencia‘s decision not to impose additional penalties related to Judge Asuncion’s bar membership, focusing the sanction solely on his judicial capacity.

This case serves as a crucial reminder to all members of the judiciary about their constitutional and ethical obligations to dispense justice promptly. It reinforces the Supreme Court’s unwavering commitment to upholding judicial accountability and ensuring that justice is not only served but also served without undue delay. The ruling underscores that prolonged inaction, especially in urgent matters, will be met with serious consequences, protecting the integrity of the judicial system and the rights of litigants to timely resolutions.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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: Castillo v. Asuncion, G.R No. 69630, August 20, 2024