G.R. No. MTJ-00-1335; November 27, 2000
YOLANDA FLORO, complainant, vs. JUDGE ORLANDO C. PAGUIO, Municipal Trial Court, Branch 1, Meycauayan, Bulacan, respondent.

FACTS

Complainant Yolanda Floro was the private complainant in multiple criminal cases for violation of B.P. Blg. 22 and estafa against an accused. The cases were submitted for decision on July 30, 1996, after the prosecution rested and the defense failed to appear. Floro filed several motions for early resolution in 1997 due to the court’s inaction. Instead of deciding, respondent Judge Paguio allowed the defense to reopen the trial and later, in a joint decision dated January 28, 1998, dismissed all cases on grounds of improper venue and lack of jurisdiction. Floro’s motion for reconsideration was denied on the ground of double jeopardy. In her administrative complaint, Floro charged Judge Paguio with gross ignorance of the law, gross misconduct, and inefficiency, highlighting his failure to decide the cases within the mandatory period and his incorrect certification of service.
In his defense, Judge Paguio argued that the motions for early resolution were ignored for lacking a notice of hearing. He claimed his July 1996 order was merely interlocutory and that the subsequent motions and reopening justified the delay. He also cited his detail as an assisting judge in another court earlier in 1996 as a reason for backlog. He maintained his dismissal on jurisdictional grounds was correct, as the checks were issued and dishonored in Makati, not Bulacan.

ISSUE

Whether respondent Judge Orlando C. Paguio is administratively liable for undue delay in rendering a decision in the subject criminal cases.

RULING

Yes, respondent Judge is administratively liable for undue delay. The Supreme Court adopted the findings of the Office of the Court Administrator (OCA) but reduced the recommended fine. The constitutional and statutory mandate requires lower courts to decide cases within three months from submission. The criminal cases were submitted for decision on July 30, 1996, making the deadline October 28, 1996. Judge Paguio failed to decide within this period, rendering his joint decision only on January 28, 1998—a delay of over fifteen months.
The Court rejected the judge’s justifications. First, the motions for early resolution filed by the complainant were non-litigable motions that did not require a notice of hearing, as the cases were already submitted for decision. These motions did not extend the prescribed period for resolution. Second, his detail to another court in early 1996 did not excuse the delay, as the cases were submitted after his return to his regular station. Third, while the Court is sympathetic to heavy caseloads, judges must manage their dockets promptly and may request extensions, which respondent failed to do. The Court emphasized that it could not rule on the substantive correctness of the dismissal in the criminal cases, as those were on appeal, but the procedural delay itself constituted inefficiency warranting administrative sanction. Consequently, Judge Paguio was fined Five Thousand Pesos (P5,000.00) with a stern warning.