A.M. No. MTJ-03-1484; January 15, 2004
DORCAS G. PETALLAR, complainant, vs. JUDGE JUANILLO M. PULLOS, MCTC, SAN FRANCISCO, SURIGAO DEL NORTE, respondent.

FACTS

Complainant Dorcas G. Petallar charged respondent Judge Juanillo M. Pullos, former presiding judge of the Municipal Circuit Trial Court of San Francisco, Surigao del Norte, with undue delay in rendering a decision in a forcible entry case (Case No. 137). Petallar alleged that the parties submitted their respective position papers and evidence on February 2, 2000. Under the Rules, judgment should have been rendered within thirty days thereafter, or by March 4, 2000. Despite follow-ups, including a formal motion for rendition of judgment filed in August 2001, no decision was issued. The complainant filed this administrative complaint on December 27, 2001.
In his comment, respondent judge stated he had rendered the decision on June 2, 2002, and argued the complaint was moot. The Office of the Court Administrator (OCA) found the decision was rendered over two years beyond the reglementary period. The OCA noted respondent failed to request an extension from the Supreme Court or provide a satisfactory explanation for the delay. The OCA recommended a fine of ₱5,000.00. Respondent judge retired from the judiciary on March 30, 2003.

ISSUE

Whether respondent Judge Juanillo M. Pullos is administratively liable for undue delay in rendering a decision.

RULING

Yes, respondent judge is administratively liable for gross inefficiency due to undue delay. The Supreme Court affirmed the OCA’s findings. Rule 70, Section 11 of the Rules of Court mandates that judgment in ejectment cases must be rendered within thirty days after receipt of the affidavits and position papers. The reglementary period expired on March 4, 2000, but the decision was rendered only on June 2, 2002—a delay exceeding two years without any authorized extension from the Court.
The legal logic is anchored on the constitutional right to a speedy disposition of cases and the mandatory periods for decision-making under the Rules of Court. Judges are strictly required to observe these periods to uphold public confidence in the judiciary. While heavy caseloads may warrant extensions, such extensions must be formally sought and granted by the Supreme Court. A judge cannot unilaterally extend the period. Respondent’s failure to decide promptly and his omission to request an extension constitute gross inefficiency, warranting administrative sanction. The Court modified the penalty, considering his retirement, and ordered a fine of ₱10,000.00 to be deducted from his retirement benefits.