G.R. No. MTJ-96-1091. March 21, 1997
Wilfredo Navarro, complainant, vs. Judge Deogracias K. Del Rosario, respondent.

FACTS

Complainant Wilfredo Navarro filed a criminal case for slight physical injuries through reckless imprudence against a driver in the Third MCTC of Patnoñgon-Bugasong-Valderrama, Antique. The case was fully tried under Judge Antonio Bantolo and submitted for decision in 1991. Judge Bantolo was transferred in 1992 without deciding the case. Respondent Judge Deogracias K. Del Rosario, Judge Bantolo’s successor, assumed office in November 1991. In December 1991, the private prosecutor filed a manifestation that the case was submitted for resolution. However, Judge del Rosario refused to decide the case, insisting that Judge Bantolo, who heard the case entirely, should be the one to render the decision. This impasse left the case undecided for over four years, prompting the complainant to file an administrative complaint for violation of the constitutional mandate on speedy disposition of cases.
In his comment, respondent Judge admitted his awareness of the submitted case but maintained his belief that Judge Bantolo should decide it. He stated he was willing to decide only if ordered. Following a directive from the Deputy Court Administrator in September 1995, respondent Judge finally rendered a decision acquitting the accused in October 1995. The Office of the Court Administrator found respondent guilty of neglect of duty, noting his prior administrative sanction for misconduct and negligence in a separate matter.

ISSUE

Whether respondent Judge Deogracias K. Del Rosario is administratively liable for his failure to decide a criminal case submitted for resolution before his court within the mandated period.

RULING

Yes, respondent Judge is administratively liable for gross neglect of duty and conduct prejudicial to the best interest of the service. The Supreme Court rejected his justification that his predecessor should decide the case. Administrative Circular No. 3-94 explicitly provides that cases submitted for decision at the time of a new judge’s appointment shall be decided by that new judge. The constitutional mandate under Section 15, Article VIII requires lower courts to decide cases within three months from submission. Respondent’s failure to decide the case for over four years constituted an inexcusable delay.
The legal logic is clear: a judge’s duty to decide cases is non-delegable and mandatory. Respondent’s deliberate refusal to act, based on a mistaken belief, transformed mere neglect into gross neglect. His inaction caused undue prejudice to both the accused, whose liberty was prolonged, and the complainant, who was denied timely justice. His prior administrative record further underscored a pattern of disregard for duties. Consequently, the Court imposed a fine of P8,000.00, modifying the OCA’s recommended penalty to reflect the gravity of his deliberate inaction, with a stern warning against repetition.