ANTONIO SOYANGCO v. JUDGE ROMEO G. MAGLALANG

FACTS:

Respondent judge in this case is being charged with gross negligence of duties, misconduct, and violation of the provisions of the Judiciary Act. The complaint against him stemmed from his failure to timely decide Criminal Case No. 3254 entitled People of the Philippines v. Lolita P. Luna, which was filed by complainant Antonio Soyangco for violation of the Bouncing Checks Law. The case was submitted for decision as early as October 1984, and as of the filing of the administrative complaint in August 1990, the decision had not yet been rendered. In his comment, respondent alleged that the decision had already been finished and ready for promulgation even before he received the complaint. He further explained that he prioritized the trial and disposition of cases for subversion, rebellion, and other criminal cases where the accused were all detained. He also mentioned that he had additional administrative duties as the Executive Judge. Respondent provided reasons for the delay in deciding the case, including a lack of research materials in his court and the need for outside legal research. The case was referred to an investigating justice, who reported that the case had already been decided and the complainant expressed his desire to desist from pursuing the complaint. The investigating justice recommended that respondent be exonerated based on the complainant's desistance. However, the Court disagreed, finding respondent guilty of dereliction of his duties as a judge. The Court concluded that the delay in deciding the case for over five years constituted gross negligence and imposed a fine on respondent.

ISSUES:

  1. Whether or not respondent judge is guilty of dereliction of his duties as judge for leaving unattended a case for violation of B.P. Blg. 22 for more than five years.

RULING:

  1. Yes, respondent judge is guilty of dereliction of his duties as judge. Failure to decide a case, particularly one involving a violation of the Bouncing Checks Law, for over five years is an inordinate amount of procrastination tantamount to gross negligence. While respondent's circumstances may serve as valid grounds for a little delay, they can only mitigate but not erase his administrative liability. Complainant's voluntary desistance from pursuing the case further does not strip the Court of its jurisdiction over respondent. The Court has administrative supervision over all courts and the power to discipline judges. Respondent judge is penalized with a fine of Eleven Thousand Pesos (P11,000.00) and warned that a repetition of the same or a similar act shall be dealt with more severely.

PRINCIPLES:

  • Failure to decide a case within a reasonable period of time constitutes dereliction of duties and gross negligence.

  • The Supreme Court has administrative supervision over all courts and the power to discipline judges.

  • The voluntary desistance of a complainant does not strip the Court of its jurisdiction to discipline erring members of the judiciary.