AM RTJ 90 570; (April, 1991) (Digest)
G.R. No. RTJ-90-570. April 19, 1991. ANTONIO SOYANGCO, complainant, vs. JUDGE ROMEO G. MAGLALANG, Regional Trial Court, Third Judicial Region, Branch 2, Balanga, Bataan, respondent.
FACTS
Complainant Antonio Soyangco filed an administrative complaint against Judge Romeo G. Maglalang for gross negligence and misconduct. The complaint stemmed from the judge’s failure to decide Criminal Case No. 3254 for violation of the Bouncing Checks Law (B.P. Blg. 22) for over five years after it was submitted for decision in October 1984. The complaint was filed on August 31, 1990.
In his comment, respondent Judge Maglalang did not deny the delay. He offered justifications, including being overburdened by handling two salas for 16 months, serving as Executive Judge with demanding administrative duties, prioritizing cases involving detained individuals and subversion, a lack of a legal researcher until 1988, and insufficient legal reference materials. During the investigation by Justice Nathanael P. de Pano, Jr., it was confirmed the case had been decided, and the complainant expressed his desire to desist from the complaint after understanding the judge’s situation.
ISSUE
Whether respondent Judge Romeo G. Maglalang is administratively liable for the inordinate delay in deciding a criminal case.
RULING
Yes, the respondent judge is administratively liable. The Court rejected the investigating justice’s recommendation for exoneration based on the complainant’s desistance. While the justifications presented by the judge—such as an excessive workload and administrative designations—may serve to mitigate liability, they cannot completely excuse the violation. The failure to decide a case, particularly a straightforward B.P. Blg. 22 case, for more than five years constitutes gross negligence and inordinate procrastination.
The Court emphasized that a judge’s duty is not only to write decisions but to promulgate them within the mandated period. Furthermore, the complainant’s desistance is immaterial to the Court’s exercise of its constitutional power of administrative supervision over all courts and judges. Administrative actions against members of the judiciary are matters of public interest and cannot be made dependent on the will of a private complainant, as this would undermine the Court’s disciplinary authority. Accordingly, Judge Maglalang was fined P11,000.00 and sternly warned that a repetition would be dealt with more severely.