G.R. No. RTJ-88-170. November 8, 1993
AGATONA ALFONSO-CORTES and LEONIDES CORTES, petitioners, vs. JUDGE RONSO MAGLALANG, respondent.

FACTS

Respondent Judge Romeo Maglalang of the Regional Trial Court of Balanga, Bataan, Branch 2, was charged with misconduct for failing to decide Civil Case No. 3810 within the 90-day reglementary period. The case, involving a foreclosed fishpond owned by complainants Agatona Alfonso-Cortes and Leonides Cortes, was submitted for decision on April 10, 1986, as evidenced by stenographic notes where the complainants’ counsel stated they were foregoing rebuttal evidence and submitting the case for decision, and the court declared the case submitted. The complainants filed their memorandum on March 5, 1987, and initiated the administrative complaint on March 9, 1987. The decision was finally promulgated on April 22, 1988. Respondent judge filed his Answer only on June 7, 1988. His defenses were: (1) the case was not submitted for decision on April 10, 1986, but later in April 1987; (2) his workload doubled starting April 14, 1987, when he was designated to handle cases in another branch; and (3) the case involved difficult legal questions requiring extensive research.

ISSUE

Whether respondent Judge Romeo Maglalang is administratively liable for failing to decide Civil Case No. 3810 within the reglementary period.

RULING

Yes, respondent judge is administratively liable. The Supreme Court found his defenses unmeritorious. First, the stenographic notes conclusively show the case was submitted for decision on April 10, 1986, with no subsequent motions to alter that submission date. Even assuming submission in April 1987, the decision rendered in April 1988 was still nine months beyond the reglementary period. Second, his workload claim is contradicted by his own testimony that from August 1987 to March 1988, his salary was withheld solely because Civil Case No. 3810 remained undecided beyond 90 days, indicating it was the only case causing such delay. Evidence showed he decided only 57 cases (including this one) from April 1987 to April 1988, averaging less than five decisions per month, which does not support an overwhelming workload. Third, the legal issues—whether the “Daily Record” was a newspaper of general circulation in Bataan and the validity of a foreclosure sale on a date different from the published date—were more factual than legal and could have been resolved without prolonged delay. The Court noted that some legal authorities cited in his decision were taken from a prior Court of Appeals ruling, undermining his claim of extensive research. The Court emphasized that failure to decide cases within the reglementary period constitutes a ground for administrative sanction, as established in Marcelino vs. Cruz, Jr., and that the delay prejudiced the complainants by prolonging the defendants’ possession of the fishpond. Respondent Judge Romeo Maglalang was found GUILTY and ordered to pay a fine of P5,000.00.