A.M. No. 1237-CAR August 21, 1980
Felicidad Castro, complainant, vs. Judge Arturo Malazo, respondent.

FACTS

This administrative case arose from complainant Felicidad Castro’s charge of undue delay against respondent Judge Arturo Malazo of the Court of Agrarian Relations (CAR) in Tayug, Pangasinan, concerning CAR Case No. 1794-TP’72 (Castro case). The Castro case and a related case, CAR No. 1822-TP’72 (Tibay case), involved conflicting claims over the same landholding. Both cases were jointly heard. The Castro case was deemed submitted for decision on September 9, 1975, after the parties filed their memoranda. Complainant wrote to the Supreme Court on January 29, 1976, alleging the judge’s failure to decide her case.
In his comment, Judge Malazo explained that he had actually decided the Castro case on September 15, 1975, but withheld its release. He stated he wanted to release it simultaneously with the decision in the closely interrelated Tibay case, which he promulgated on February 26, 1976. The complainant countered that the judge only prepared the decision after her complaint to the Supreme Court and that his reason for the delay was unjust. An investigation by Justice Corazon Agrava confirmed the decision was indeed signed on September 15, 1975, as per a stipulation of facts and a monthly report, but it was only filed with the Clerk of Court on February 26, 1976.

ISSUE

Whether respondent Judge Arturo Malazo is administratively liable for undue delay in deciding CAR Case No. 1794-TP’72.

RULING

Yes, respondent Judge is administratively liable. The Supreme Court found him guilty of undue delay and reprimanded him. The legal logic is anchored on the mandatory period for deciding agrarian cases under Section 151 of Republic Act No. 3844 (Agricultural Land Reform Code), which requires decisions within thirty (30) days after the case is submitted for resolution. The Court rejected the judge’s justifications. First, the claim that the two cases were “closely interrelated” was belied by his own admission that they involved different causes of action. The Court reasoned that the possibility of revealing a common issue in one decision was not a valid excuse, as decisions are appealable. Second, the act of filing a signed decision with the clerk of court is a ministerial duty; the period for decision is reckoned from submission to the date of such filing or release, not merely from the date of signing.
The interval from the submission on September 9, 1975, to the filing on February 26, 1976, spanned 170 days, far exceeding the 30-day statutory limit. The Court emphasized that excusing such a delay would render the legal mandate useless and obstruct the speedy administration of justice, a principle consistently upheld in jurisprudence. While the judge signed the decision within six days, the prolonged withholding of its release constituted the delay. The Court admonished the judge to strictly comply with the law, warning that a repetition would be dealt with more severely.