G.R. No. A.M. No. 2112-CFI and A.M. No. 2123-CFI December 29, 1980
JOSE MANGULABNAN and DOLORES BOLILAN, complainants, vs. JUDGE JOSE TECSON and ATTY. RAYMUNDO MAGNO, respondents.

FACTS

Complainants Jose Mangulabnan and Dolores Bolilan were the complaining witnesses in two consolidated estafa cases. The cases were submitted for decision on August 16, 1977. The complainants repeatedly inquired with respondent Branch Clerk of Court Atty. Raymundo Magno about the status of the decision, sending formal letters in January 1978 and several follow-ups, but received no response. Complainant Bolilan even personally visited respondent Judge Jose Tecson in July 1978 but was mistakenly told the case was still under study.
It was later revealed that respondent Judge had actually rendered a joint decision on February 24, 1978, or six months after submission. However, due to an alleged misfiling by a since-resigned clerk, the records were misplaced. A copy of this decision was furnished to complainant Mangulabnan only on September 28, 1979—over 19 months after its rendition and after the cases had already been appealed to the Court of Appeals. The complainants charged the respondents with non-feasance for the inordinate delay and failure to act on their inquiries.

ISSUE

Whether respondents Judge Jose Tecson and Atty. Raymundo Magno are administratively liable for the delay in the promulgation and release of the decision and for their failure to properly attend to the complainants’ inquiries.

RULING

Yes, the respondents are administratively liable. The Supreme Court found them remiss in their official duties, warranting a reprimand. The legal logic centers on the constitutional mandate for the speedy disposition of cases. While the decision was rendered within a reasonable period (six months), the subsequent failure to promulgate and release it for over 19 months constituted a grave neglect that undermined this constitutional principle.
The Court rejected the respondents’ justifications. Judge Tecson’s explanation of misfiling and cramped office space, coupled with his personal miscommunication with complainant Bolilan, demonstrated a lack of effective control over court records and personnel. His duty extends beyond merely writing decisions; it includes ensuring their proper promulgation and communication to interested parties. Clerk of Court Magno was likewise negligent for ignoring the complainants’ multiple written inquiries. His defense that copies are typically furnished only to lawyers does not absolve him from the duty to respond to legitimate requests from parties-in-interest regarding public records. Their collective inaction bred suspicion and defeated the very purpose of a judicial decision. The Court emphasized that a decision unknown to the winning party is useless and can become a tool for manipulation. Therefore, both respondents were reprimanded and sternly warned that a repetition would be dealt with more severely.