CASE BRIEF 2003-0683

CASE: Atty. Procopio S. Beltran, Jr.  vs. Judge Maximo G. Paderanga, RTC-Br. 38, Cagayan de Oro City (A.M. No. RTJ-03-1747 July 31, 2003)

PONENTE: Bellosillo, J.:

SUBJECT:

  1. Evidence: Offer of evidence; Objection
  2. Code of Judicial Conduct: Canon 3 (Adjudicative Responsibilities)

FACTS: In a civil case, Atty. Procopio S. Beltran Jr. was the plaintiff’s counsel of record while Judge Maximo Paderanga is the Presiding Judge.

After the presentation of evidence, plaintiff, through Atty. Beltran, filed a Motion to Admit Formal Offer of Exhibits. However, since the motion contained confusing references to the exhibits, Judge Paderanga wasconstrained to give Atty. Beltranb another ten (10) days to make “an orderly and proper offer of exhibits”.

As a result of the errors of Atty. Beltran, the presentation of the evidence for the defense was deferred from 23 April 2001 to a later date to be determined “only after the matter [i.e., admission of plaintiff’s offer of exhibits] shall have been resolved by the Court.” 

On 5 June 2001 Judge Paderanga received from Atty. Beltran, in behalf of plaintiff, an Amended Formal Offer of Exhibits with Apology for his gaffe. Unfortunately, Judge Paderanga failed to rule on the offer of exhibits within a reasonable time and to expedite the trial of the civil case; his omission in fact delayed the progress of the case since the defense evidence was to be presented only after plaintiff’s offer of exhibits was resolved. It was only on 6 March 2002 when Atty. Beltran filed a Manifestation asking Judge Paderanga to rule on plaintiff’s Amended Formal Offer of Exhibits that Judge Paderanga realized his “miscue” and issued his Order of 7 March 2002 admitting plaintiff’s formal offer of exhibits after nine (9) long months.

Judge Paderanga admits his “actions and inactions” and apologizes for his “shortcomings” and “inadequacies.” He however proffers an excuse: he had misplaced the case folder of civil case and believed in good faith.  With Judge Paderanga’s admission, he and Atty. Beltran submitted this administrative case for our resolution.

ISSUE:        Whether Judge Paderanga should be held liable.

RULING:

Judge Paderanga is administratively liable for the delay of nine (9) months in resolving a routine and perfunctory Amended Formal Offer of Exhibits. 

Actionable tardiness in resolving controversies and incidents therein violates Rule 3.05 of the Code of Judicial Conduct which requires a judge to “dispose of the court’s business promptly and decide cases within the required periods.” Under the Rules of Court, a judge is mandated to rule on every offer of testimonial and documentary evidence “immediately after the objection is made, unless the court desires to take a reasonable time to inform itself on the question presented,” but the ruling “shall always be made during the trial and at such time as will give the party against whom it is made an opportunity to meet the situation presented by the ruling.” In any event, a reasonable time must not extend beyond the ninety (90)-day reglementary period from the date of submission of the formal offer of evidence.

Moreover, the delay of nine (9) months cannot be excused by Judge Paderanga’s allegation that he had misplaced the appropriate folders of the civil case. Incompetent court management does not help him explain and gloss over a serious violation of the constitutional right to speedy disposition of cases which was brought about by his failure to resolve incidents within the period fixed by law. In fact, such Judge Paderanga’s inefficiency bolters the allegation of his culpable omission since it is his responsibility as well to “organize and supervise the court personnel to ensure the prompt and efficient dispatch of business and require at all times the observance of high standards of public service and fidelity.” A well-organized court includes the proper physical inventory of cases which is as much Judge Paderanga’s duty as his adjudicative functions, for which he is provided a court staff and a branch clerk of court who assist him in accomplishing these tasks.

The requirement that cases be decided within the reglementary period is designed to prevent delay in the administration of justice, for obviously, justice delayed is justice denied. An unwarranted slow down in the disposition of cases erodes the faith and confidence of our people in the judiciary, lowers its standards and brings it into disrepute.
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THINGS DECIDED:

A)      Under the Rules of Court, a judge is mandated to rule on every offer of testimonial and documentary evidence “immediately after the objection is made, unless the court desires to take a reasonable time to inform itself on the question presented,” but the ruling “shall always be made during the trial and at such time as will give the party against whom it is made an opportunity to meet the situation presented by the ruling.” In any event, a reasonable time must not extend beyond the ninety (90)-day reglementary period from the date of submission of the formal offer of evidence.

B)       Rule 3.05 of the Code of Judicial Conduct requires a judge to “dispose of the court’s business promptly and decide cases within the required periods.”

C)      The requirement that cases be decided within the reglementary period is designed to prevent delay in the administration of justice, for obviously, justice delayed is justice denied.

‘Stand by things decided’ ~ Stare Decisis


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