The Supreme Court ruled in this case that judges have a responsibility to act on pending motions promptly. Undue delay in resolving a case or a motion not only prejudices the parties involved but also erodes public trust in the judicial system. The Court imposed fines on Judge Lizabeth G. Torres for her failure to act on a motion to withdraw information for over five years and for ignoring the Court’s directives to comment on the administrative complaint against her. This decision highlights the importance of judicial efficiency and the consequences for failing to meet the expected standards of conduct.

The Case of the Stalled Motion: When is Justice Truly Served?

This case revolves around a complaint filed by Michael Gamaliel Plata against Judge Lizabeth G. Torres of the Metropolitan Trial Court in Cities, Branch 60, Mandaluyong City. Plata accused Judge Torres of grave abuse of discretion, gross negligence, serious inefficiency, and violation of the Code of Judicial Conduct for failing to resolve a Motion to Withdraw Information in a criminal case filed against him. The motion, filed by the Assistant City Prosecutor on July 29, 1999, remained unacted upon for over two years, prompting Plata to file a manifestation for its early resolution. Despite this, Judge Torres failed to take any action, leading Plata to file an administrative complaint.

The backdrop of this case began with Plata being accused of attempted homicide. However, the Department of Justice (DOJ) later reversed the City Prosecutor’s resolution and directed the withdrawal of the information. In accordance with this directive, the prosecutor filed a Motion to Withdraw Information, but the respondent Judge failed to act on it for an unreasonable period. This inaction, according to Plata, violated his constitutional right to a speedy disposition of the case against him. His anxiety was amplified as the case lingered unresolved, affecting his lawful rights, tasks, and reputation.

Adding to the gravity of the situation, Judge Torres repeatedly failed to comply with the Supreme Court’s directives to comment on the administrative complaint. Despite multiple extensions and warnings, she only submitted her explanation and comment more than three years after the initial request. The Office of the Court Administrator (OCA) investigated the matter and found Judge Torres liable, recommending a fine. The OCA emphasized that while Judge Torres assumed her position after the initial filing of the motion, it was her responsibility to resolve the pending incident within a reasonable time.

The Supreme Court agreed with the OCA’s findings, underscoring that rules prescribing time limits for official acts are indispensable for preventing delays and ensuring the orderly conduct of official business. The 1987 Constitution mandates trial judges to promptly dispose of the court’s business and decide cases within three months from the filing of the last pleading. Canon 6 of the Code of Judicial Ethics also explicitly directs judges to be prompt in resolving matters submitted to them, reinforcing the principle that delayed justice is often justice denied. As the Court stressed:

He should be prompt in disposing of all matters submitted to him, remembering that justice delayed is often justice denied.

In her defense, Judge Torres cited an overwhelming workload, a lack of court personnel, and marital problems as reasons for the delay. She claimed to have inherited a massive backlog of cases and had to attend to additional cases as a pairing Judge and Executive Judge. However, the Court found these justifications insufficient to exonerate her, noting that she could have sought an extension if she was unable to meet the deadline. Thus, while acknowledging the challenges faced by judges, the Supreme Court made it clear that failure to seek an extension when facing unavoidable delays is not excusable negligence.

Ultimately, the Supreme Court found Judge Torres guilty of undue delay in resolving the Motion to Withdraw Information and for repeatedly disregarding the Court’s orders. Considering the mitigating circumstances, the Court imposed a fine of P10,000.00 for the undue delay and another fine of P10,000.00 for her failure to comply with the Court’s directives. The Court also warned that any repetition of these or similar offenses would be dealt with more severely. Her liability was further increased by repeatedly ignoring the orders of the court.

FAQs

What was the key issue in this case?	The key issue was whether Judge Torres should be held administratively liable for undue delay in resolving a Motion to Withdraw Information and for failing to comply with the Supreme Court’s directives.
What was the basis of the complaint against Judge Torres?	The complaint was based on Judge Torres’ failure to act on a motion for over five years and her repeated failure to respond to the Supreme Court’s orders to comment on the administrative complaint.
What mitigating circumstances did Judge Torres present?	Judge Torres cited an overwhelming workload, lack of court personnel, and marital problems as reasons for the delay in resolving the motion.
What sanctions were imposed on Judge Torres?	The Supreme Court imposed a fine of P10,000.00 for undue delay in resolving the motion and another fine of P10,000.00 for her failure to comply with the Court’s directives.
What duty does the constitution put on judges?	The 1987 Constitution mandates that trial judges should dispose of the court’s business promptly and decide cases within three months from the filing of the last pleading, brief or memorandum.
What is Canon 6 of the Code of Judicial Ethics?	Canon 6 directs judges to be prompt in resolving all matters submitted to them, emphasizing that delayed justice is often justice denied.
What should a judge do if unable to make a timely decision?	The Supreme Court stated that if a judge cannot make a decision by the mandated deadline, they may request an extension, giving valid reasons for the request.
What did the court say about disregarding its directives?	The Court found Judge Torres showed disrespect to the court, emphasizing its directives aren’t just requests. This negligence constitutes misconduct and insubordination.

This case serves as a reminder of the judiciary’s responsibility to ensure swift and efficient justice. Judges are expected to resolve matters promptly, adhering to the timelines set by law and respecting the directives of the Supreme Court. Failure to do so can result in disciplinary action, impacting not only the judge but also the public’s perception of the justice system.

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: MICHAEL GAMALIEL PLATA VS. JUDGE LIZABETH G. TORRES, 47566, October 24, 2008