G.R. No. A.M. No. 1171-MJ November 17, 1980
MARCELINO SINGSON, SR., complainant, vs. MUNICIPAL JUDGE PABLO L. VILLANUEVA of Tabuk, Kalinga-Apayao, respondent.

FACTS

Criminal Case No. 1119 for homicide through reckless imprudence was filed against Henry Manuit in the municipal court of Tabuk, Kalinga-Apayao, on June 30, 1972. The case was submitted for decision on July 30, 1973. Respondent Judge Pablo L. Villanueva rendered his decision only on November 13, 1975, resulting in a delay of over two years from the submission date. The decision convicted Manuit and imposed an indeterminate penalty and damages.
Complainant Marcelino Singson, Sr., the father of the victim, filed an administrative complaint on November 24, 1975, denouncing the judge for gross neglect of duty for failing to decide the case promptly. Singson also raised an ancillary complaint regarding the allegedly low bail bond of three thousand pesos set for the accused, which he argued was insufficient given that there were four victims involved in the incident.

ISSUE

Whether respondent Judge Pablo L. Villanueva is administratively liable for the undue delay in deciding Criminal Case No. 1119 and for setting an allegedly inadequate bail bond.

RULING

Yes, the respondent judge is administratively liable. The Supreme Court held that the delay of more than two years in rendering the decision was inexcusable and constituted a failure to perform judicial duties properly, in violation of Section 97 of the Judiciary Law. The Court rejected the judge’s justifications, which included the lack of a separate chamber, frequent disturbances, the resignation of his clerk of court, the need to personally type decisions, and heavy caseload. The Court emphasized that such administrative and logistical challenges, while unfortunate, do not absolve a judge from the mandatory duty to decide cases within the prescribed period. The Court noted that the judge himself had indicated in his monthly certificates of service that cases remained undecided beyond the ninety-day period, demonstrating awareness of the backlog.
Regarding the bail bond, the Court found that the respondent judge should have fixed a higher amount. The Court suggested that the inadequate bail might have enabled the accused to jump bail, evade arrest, and avoid the promulgation of the judgment, as the accused remained at large at the time of the investigation. Consequently, the Supreme Court severely censured Judge Villanueva for the undue delay and ordered him to pay a fine equivalent to one month’s salary. A copy of the decision was ordered to be attached to his personal record.