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ATTY. REYNALDO Q. MARQUEZ v. JUDGE ARCADIO I. MANIGBAS

This case has been cited 1 times or more.

2015-03-17
BERSAMIN, J.
Justice YbaƱez, as the ponente for C.A. G.R. SP No. 108807, carried the case with him when he was transferred to the 13th Division. But whether or not he was administratively liable for the delay of eight months should depend on the relevant circumstances. Although often holding that a heavy caseload is insufficient reason to excuse a Judge from disposing his cases within the reglementary period,[22] the Court has applied this rule by considering the causes of the delay. In Marquez v. Manigbas,[23] the Court relieved the respondent judge from liability because the delay had been caused by the sudden deluge of cases brought about by the expansion of the jurisdiction of the municipal trial courts. In Santos v. Lorenzo,[24] the Court held that a delay of seven months in deciding a case could be excused because of the heavy caseload of the trial courts in the National Capital Judicial Region. In Lubaton v. Lazaro,[25] the Court, in sparing the respondent from the sanctions earlier imposed for undue delay, cited the good faith of the judge, the motivation of the complainant for bringing the charge, and the excessively heavy caseload of 3,500 cases, 1,800 of which involved detainees, leaving her only Fridays for the study of her cases and the resolution of pending incidents and issuance of the proper orders. The Court, in reversing the sanctions, observed that "it would be unkind and inconsiderate on the part of the Court to disregard respondent Judge's limitations and exact a rigid and literal compliance with the rule."[26]