Upholding Judicial Duty: Prompt Resolution of Cases and the Consequences of Undue Delay

The Constitution fixes a deadline for every case and motion submitted for resolution, and courts are expected to meet it. In Mina v. Judge Jesus B. Mupas (A.M. No. RTJ-07-2067, June 18, 2008; 578 Phil. 41), the Supreme Court held a Regional Trial Court judge administratively liable for issuing an order several months past that deadline. The ruling matters to anyone with a pending case: delay is not merely a discourtesy to litigants, it is a ground for administrative sanction against the judge.

The complaint: a motion left unresolved

Nilo Jay Mina was the plaintiff in a civil case for damages pending before the Regional Trial Court, Branch 112, Pasay City, presided over by Judge Mupas. In a letter-complaint dated January 2, 2007, Mina alleged that his Urgent Motion to Declare All Defendants in Default, received by the court on May 12, 2006, had remained unresolved for more than seven months. He accused the judge of dereliction of duties, grave misconduct, manifest partiality, and violations of the Constitution and the Anti-Graft and Corrupt Practices Act. The Office of the Court Administrator (OCA) took up the matter, and the Court eventually referred it to Court of Appeals Justice Martin S. Villarama, Jr. for investigation, report and recommendation.

The judge's defense

In his Comment, Judge Mupas admitted that the motions were resolved beyond the reglementary period, but explained that he had already issued an order resolving the urgent motion and two motions to dismiss on December 18, 2006. Copies of that order, however, were inadvertently not served on the complainant and one of the defendants. He added that he was handling two branches,