G.R. No. RTJ-96-1338. September 5, 1997.
ENGINEER FERNANDO S. DIZON, complainant, vs. JUDGE LILIA C. LOPEZ, Regional Trial Court, Branch 109, Pasay City, respondent.

FACTS

Complainant Fernando S. Dizon was convicted of falsification of a private document by respondent Judge Lilia C. Lopez in a decision dated April 22, 1993. The promulgation on that date consisted only of reading the dispositive portion, sentencing him to imprisonment. The court did not serve a copy of the full decision. Despite repeated attempts by complainant and his father, they could not obtain a copy. Complainant filed a partial motion for reconsideration on May 5, 1993, reserving his right to file a more elaborate motion upon receipt. The hearing for this motion was not held as scheduled because the decision was reportedly not finished. It was only on December 16, 1994, after complainant filed an omnibus motion to annul the promulgation, that he was finally served a copy of the 1993 decision.
Complainant filed an administrative complaint, alleging respondent judge violated constitutional provisions requiring decisions to state facts and law clearly and to be rendered within three months, denied his right to a speedy trial, and committed falsification by antedating the decision and including an additional fine. Respondent judge explained the delay was unintentional, citing an overwhelming caseload with limited staff, and a series of personal tragedies including the deaths of close family members and her own serious health issues. She voluntarily inhibited herself from the case after complainant moved for her disqualification.

ISSUE

Whether respondent Judge Lilia C. Lopez is administratively liable for the delay in furnishing a copy of the decision to the convicted accused.

RULING

Yes, respondent judge is administratively liable for inefficiency, but the other charges lack merit. The Supreme Court found that respondent violated Article VIII, Section 15(1) of the Constitution, which mandates that lower courts decide or resolve cases within three months from submission. While the written decision, when finally released, contained the requisite factual and legal bases—negating the charge of rendering a decision without such bases—the inordinate delay of over one year and eight months in serving a copy constituted a failure to decide the case within the constitutional period. The Court clarified that the period for an accused to appeal or move for reconsideration only begins upon actual receipt of the decision, so complainant suffered no legal prejudice to his appellate rights, though he endured the anxiety of a conviction without knowing its basis.
The Court considered mitigating factors. Respondent’s long and otherwise unblemished record in public service, the overwhelming volume of her court’s caseload with inadequate staff, and the severe personal hardships she endured (multiple family deaths, financial reverses, and her own diabetes and hypertension) were taken into account. Comparing the circumstances to a prior case (Mangulabnan v. Tecson) where a judge was reprimanded for a similar delay due to less compelling reasons, the Court deemed a reprimand as the appropriate penalty. Respondent Judge Lilia C. Lopez was REPRIMANDED and WARNED that a repetition would be dealt with more severely.