When Judges Face Accountability: The Pajaron Contempt Case Explained

The Constitution gives every litigant the right to a speedy disposition of cases. When a judge fails to decide cases within the reglementary period, that right is violated—and the judge faces administrative liability, even after retirement. In Office of the Court Administrator v. Pajaron (A.M. No. RTJ-15-2432, October 6, 2021), the Supreme Court reminded the judiciary that the duty to decide promptly is non-negotiable.

The Facts of the Case

The case began with a letter from the Clerk of Court of Branch 10, Regional Trial Court (RTC), Abuyog, Leyte, reporting a backlog of cases submitted for decision before then-Presiding Judge Buenaventura A. Pajaron. An audit by the Office of the Court Administrator (OCA) covering January 2013 to October 2014 revealed that 66 cases—43 criminal and 23 civil—had remained undecided well beyond the reglementary period.

Some cases had been pending for at least three years. The judge offered several explanations: lack of personnel, the aftermath of Super Typhoon Yolanda, and his own health issues. He also claimed to have disposed of 22 cases in October and November 2014.

The Issue

The central question was whether Judge Pajaron should be held administratively liable for gross neglect of duty, gross inefficiency, and dishonesty for failing to decide cases within the required period and for falsely certifying that he had done so.

The Court's Ruling

The Supreme Court found Judge Pajaron guilty of gross inefficiency and dishonesty. He was ordered to pay a fine of Php100,000.00, to be deducted from his retirement benefits.

The Constitutional Duty to Decide Promptly

Section 15(1), Article VIII of the 1987 Constitution requires lower courts to decide cases within three months from the date of submission. This is reinforced by:

• Section 5, Canon 6 of the New Code of Judicial Conduct, which requires judges to perform judicial duties efficiently, fairly, and with reasonable promptness.
• Rule 3.05, Canon 3 of the Code of Judicial Conduct, which mandates prompt disposition of court business.

The Court stressed that judges are held to a higher standard. Failure to decide within the required period violates every litigant's constitutional right to speedy disposition and constitutes gross inefficiency.

The Dishonesty Finding

Judge Pajaron's monthly certificates of service from March 2014 to January 2015 stated that he had "decided and resolved all incidents within three (3) months from the date of submission." These certifications were false—the monthly reports showed dozens of unresolved cases during the same period. This constituted dishonesty, a serious charge under Rule 140 of the Revised Rules of Court.

Why the Fine Was Reduced

The OCA initially recommended a fine of Php200,000.00. The Court reduced it to Php100,000.00, considering:

• This was the judge's first offense of this nature.
• He had resolved all but one of the 66 undecided cases.
• He had rendered 39 years of government service, all in the judiciary.

The Court cited prior cases, including Re: Emuslan (A.M. No. RTJ-10-2226) and Re: Tirso F. Banquerigo (A.M. No. MTJ-20-1938), to illustrate the range of penalties imposed in similar situations.

Practical Takeaways

• The 90-day rule is absolute. Judges must decide cases within three months from submission, barring exceptional circumstances.
• Natural disasters and staffing issues are not automatic excuses. While these may explain delays, they do not excuse a judge from the duty to decide, especially when cases were submitted before such events occurred.
• Certificates of service must be truthful. Falsely certifying that all cases have been decided is dishonesty—a serious offense with severe penalties.
• Retirement does not shield a judge from liability. Administrative cases may proceed even after a judge's compulsory retirement, with fines deductible from retirement benefits.
• Litigants have remedies. Parties awaiting decisions beyond the reglementary period may file administrative complaints or seek appropriate relief from the courts.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.