G.R. No. RTJ-02-1680. January 28, 2003.
VICENTE A. PICHON, complainant, vs. JUDGE LUCILO C. RALLOS, Former Presiding Judge of the Regional Trial Court of Tagum City, Branch 1, respondent.

FACTS

Complainant Vicente A. Pichon, the private complainant in three estafa cases (Criminal Cases Nos. 7840-42), charged respondent Judge Lucilo C. Rallos with incompetence for undue delay in deciding said cases. The complainant averred that the cases were submitted for decision in October 1995 but remained undecided despite repeated follow-ups. In his defense, Judge Rallos disclaimed responsibility, asserting he never presided over any trial stage. He argued that under Administrative Circular No. 3-94, the cases should be decided by former Judge Agnes Reyes-Carpio, to whom they were allegedly submitted.
A judicial audit and records from the Office of the Court Administrator (OCA) revealed a different factual backdrop. The cases passed through several judges. After the defense rested and the prosecution waived rebuttal, it was respondent Judge Rallos himself who, in an Order dated August 25, 1995, directed the parties to submit their memoranda. The parties complied. Subsequently, a court officer certified in 1998 that the records and transcripts were with Judge Rallos for decision preparation. Furthermore, the Supreme Court, in a prior resolution (A.M. No. 00-7-322-RTC dated August 16, 2000), had explicitly directed Judge Rallos to decide these very cases, which he eventually did on September 25, 2000.

ISSUE

Whether respondent Judge Lucilo C. Rallos should be held administratively liable for the delay in deciding Criminal Cases Nos. 7840-42.

RULING

Yes, Judge Rallos is administratively liable. The Court found his defense unavailing. The Code of Judicial Conduct mandates judges to dispose of court business promptly and decide cases within required periods (Canon 3, Rule 3.05). Delay undermines public confidence in the judiciary. The record conclusively established Judge Rallos’s direct responsibility: he issued the order for the final memoranda, and the case records were formally submitted to him for decision. His claim of non-involvement was contradicted by the audit findings and the Supreme Court’s own prior directive identifying him as the judge obligated to decide the cases.
The legal logic is clear: once a case is submitted to a judge for decision, the duty to decide it seasonably attaches personally to that judge. Judge Rallos’s failure to act promptly or, if he genuinely believed otherwise, to promptly seek clarification from the Court Administrator instead of letting the cases languish, constituted gross inefficiency and dereliction of duty. However, considering his lack of prior administrative record and the OCA’s recommendation, the penalty imposed was a reprimand with a warning.