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Judge Quiñanola Neglect Case Verdict

Judge Leonardo Quiñanola was found to have a massive backlog of 1268 cases and 47 pending matters by the Office of the Court Administrator near his retirement. The branch clerk of court, Ruben Albaytar, also failed to submit required semi-annual reports on pending cases. The OCA recommended fines for the judge and reprimand for the clerk. The Supreme Court ruled the judge was guilty of gross inefficiency for failing to decide cases within the required 90-day period, fining him ₱40,000. The clerk was reprimanded.

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152 views1 page

Judge Quiñanola Neglect Case Verdict

Judge Leonardo Quiñanola was found to have a massive backlog of 1268 cases and 47 pending matters by the Office of the Court Administrator near his retirement. The branch clerk of court, Ruben Albaytar, also failed to submit required semi-annual reports on pending cases. The OCA recommended fines for the judge and reprimand for the clerk. The Supreme Court ruled the judge was guilty of gross inefficiency for failing to decide cases within the required 90-day period, fining him ₱40,000. The clerk was reprimanded.

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NMNG
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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FULL TITLE AS IN FULL TEXT: OFFICE OF THE COURT ADMINISTRATOR vs. Judge LEONARDO F.

QUIÑANOLA and Branch Clerk of Court RUBEN B. ALBAYTAR, MTC of San Pedro, Laguna
A.M. No. MTJ-99-1216
DATE: OCTOBER 20, 1999
PONENTE: J., Panganiban
TOPIC: Neglect of Duty

FACTS OF THE CASE:


Near Respondent Judge Quinanola’s impending compulsory retirement, it was found by the Office of the
Court Administrator (OCA) in their judicial and physical inventory that the retiring Judge had a massive backlog
of 1268 cases and 47 interlocutory matters awaiting resolution, among other details that showed the Judge and his
Clerk of Court’s gross neglect of their duties. It was also discovered that the Branch Clerk of Court Albaytar had
failed to submit semi-annual reports on all the pending cases, as should be prescribed by Administrative Circular
No. 10-94.

PROCEDURAL HISTORY:
The OCA required the comments of the respondents. Judge Quinanola submitted that his heavy workload
in 1993 and his subsequent cerebral hematoma in 1994 caused the massive backlog while Branch Clerk of Court
Albaytar reasoned out that he misapprehended Administrative Circular No. 10-94 in detriment of his duties.
In its Memorandum , the OCA, through Deputy Court Administrator Zenaida N. Elepaño, recommended
that respondent judge be fined in the amount of P40,000 and respondent clerk of court be reprimanded.

STATEMENT OF ISSUE/S: Whether or not Judge Quinonla and Branch Clerk of Court Albaytor constitutes
gross negligence of their duties and warrants administrative sanctions

HOLDING:
YES. This court has always emphasized the need and the imperative for judges to decide cases promptly
and expeditiously within the constitutionally prescribed 90-day period. Their failure to do so constitutes gross
inefficiency, which consequently warrants administrative sanctions.
In this case, respondent judge was remiss in the performance of his duties. As borne out by the findings of
the OCA, he failed to decide 12 cases within the prescribed period and to resolve matters pending in forty-one 41
others. The OCA recommendation was well-taken and applied. The failure of a judge to decide cases promptly
and expeditiously within the constitutionally prescribed 90-day period constitutes gross inefficiency, which
consequently warrants administrative sanctions.
Judge Leonardo F. Quiñanola was found GUILTY of gross efficiency and gross misconduct, and was
hereby ordered to PAY a fine of forty thousand pesos (P40,000) to be taken from his retirement benefits. Branch
Clerk of Court Ruben Albaytar was REPRIMANDED.

Notes, if any:
Section 15. (4) Despite the expiration of the applicable mandatory period, the court, without prejudice to such
responsibility as may have been incurred in consequence thereof, shall decide or resolve the case or matter
submitted thereto for determination, without further delay.

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