SC punishes judge for undue delay in deciding cases


Pursuant to a judicial audit and physical inventory of the pending cases at the Regional Trial Court, Branch 75, Valenzuela City (RTC), following the resignation of its Presiding Judge, Trinidad L. Dabbay (Judge Dabbay), effective July 1, 2009, the Court, in its Resolution[1], dated March 8, 2010, directed Judge Dabbay to explain his failure to decide within the reglementary period 16 criminal cases and 50 civil cases; to resolve within the reglementary period pending motions/incidents in 37 criminal cases and 132 civil cases; and to take appropriate action on 18 criminal cases and 157 civil cases which were not acted upon for a considerable length of time.

In his letter,[2] Judge Dabbay cited the volume and pressure of work as well as his health as reasons for his inability to cope with the overcrowded docket of the court.

In its Memorandum,[3] dated June 28, 2013, the Office of the Court Administrator (OCA) recommended that:
the instant administrative matter be RE-DOCKETED as a regular administrative complaint against respondent former Judge Trinidad L. Dabbay, Branch 75, RTC, Valenzuela City;
respondent former Judge Dabbay be found GUILTY of delay in rendering decisions and FINED in the amount of Twenty Thousand Pesos (Php20,000.00) payable within thirty (30) days from receipt of notice; and
respondent former Judge Dabbay be served a copy of the Court's resolution on the instant matter at the residential address appearing in his 201 File, i.e., 114 Isarog Street, La Loma, Quezon City.
The Court agrees with the recommendation of the OCA, except as to the penalty.Section 15, Article VIII of the 1987 Constitution requires lower courts to decide or resolve cases or matters for decision or final resolution within three (3) months from date of submission. Complementary to this constitutional provision is Canon 1, Rule 1.02, of the Code of Judicial Conduct which instructs that a judge should administer justice impartially and without delay.

Similarly, Canon 3, Rule 3.05 of the Code of Judicial Conduct enjoins judges to dispose of their business promptly and to decide cases within the required period. All cases or matters must be decided or resolved by all lower courts within a period of three (3) months from submission.

The Court has consistently reminded all judges to meticulously observe the period prescribed by the Constitution for deciding cases because failure to comply with the said period transgresses the parties' constitutional right to speedy disposition of their cases.[4]

Considering, however, that Judge Dabbay had no prior infraction and was in poor health, the Court finds that a fine of P10,000.00 is reasonable.

WHEREFORE, the Court RESOLVES to ADOPT and APPROVE the recommendation of the Office of the Court Administrator. Accordingly, the Court FINDS former Judge Trinidad L. Dabbay, Regional Trial Court, Branch 75, Valenzuela City, GUILTY of undue delay in rendering decisions and FINES him in the amount of TEN THOUSAND PESOS (P10,000.00) to be deducted from the benefits due and payable to him.


[1] Rollo, pp. 86-119.[2] Id. at 124-128.
[3] Id. at 142-144.
[4] Cabasares v. Judge Tandinco, Jr., A.M. No. MTJ-11-1793 [Formerly A.M. OCA IPI No. 10-2238-MTJ], October 19, 2011, 659 SCRA 396, 402.