Facts:

This case involves Corazon Guerrero as the complainant against Judge Marcial M. Deray, who presides over the 12th Municipal Circuit Trial Court of Mallig-Quezon, Isabela. The letter-complaint was filed on August 22, 2000, alleging that Judge Deray had unduly delayed the resolution of Criminal Case No. 1903, "People of the Philippines v. Rolando Guerrero," which was initiated on June 12, 1997. The accused, Rolando Guerrero - the complainant's husband - was arrested on June 13, 1997, on charges of rape. The complainant asserted that Judge Deray had conducted the preliminary examination and terminated it in 1998; however, as of the filing date of the complaint, no resolution had been issued, leaving her husband incarcerated for over three years. Despite multiple inquiries made by the complainant regarding the status of the case, she was informed at the court that the resolution had been sent to the Office of the Provincial Prosecutor, which later confirmed that no suc

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Facts:

Background of the Case

• Corazon Guerrero, the legitimate spouse of the accused in Criminal Case No. 1903 ("People of the Philippines v. Rolando Guerrero"), filed an administrative letter-complaint on August 22, 2000, against Judge Marcial M. Deray.
• The complaint centers on the alleged delay in resolving the preliminary examination in the criminal case involving rape.

Chronology and Procedural History

• The criminal complaint was filed on June 12, 1997, against Rolando Guerrero.
• Accused was arrested on June 13, 1997, by the local police, later transferred to the Bureau of Jail Management and Penology.
• Despite Judge Deray conducting the preliminary examination as early as 1998, no resolution was ever forwarded despite repeated inquiries by the complainant and several motions filed by the accused’s counsel.
• On February 12, 2001, a resolution directed the parties to manifest their willingness to submit the case based on the pleadings. While the complainant complied on March 29, 2001, Judge Deray failed to submit his compliance.

Respondent Judge’s Explanations and Actions

• Judge Deray claimed that delays were partly due to external factors:
• The complainant (as wife of the accused) had involved local officials to negotiate a compromise with a private complainant, which purportedly held the case in abeyance.
• After the negotiations fell through, he brought the case records home to study them and subsequently lost the record, which was later found among old newspapers by his mother-in-law.
• He asserted that a resolution dated September 4, 2000, had been issued, finding a prima facie case for multiple rape; however, the resolution was never transmitted to the Provincial Prosecutor for appropriate action.

Findings by the Office of the Court Administrator (OCA) and Subsequent Developments

• The OCA found Judge Deray guilty of delay in resolving the preliminary investigation and recommended a fine of Five Thousand Pesos (P5,000.00) with a warning against recurrence.
• Additional evidence, including a letter dated June 25, 2002, from the Information Officer of Quezon, Isabela, confirmed that over five years had elapsed without resolution of the preliminary examination.
• The prolonged delay resulted in the accused languishing in jail without formal charges being filed in a court of law.

Judicial Context and Related Considerations

• The conduct of judges in handling preliminary investigations has been scrutinized, as it is a non-judicial function subject to review and disciplinary oversight.
• The case emphasizes that judicial timeliness is critical: delays infringe on constitutional rights such as the right to a speedy trial and due process.
• The records reveal not only negligence in case management (loss of records, failure to forward documents) but also possible misrepresentation by Judge Deray regarding his resolution of the case.

Outcome and Disciplinary Sanctions Imposed

• Respondent Judge Marcial M. Deray was found guilty of gross incompetence and inefficiency, gross misconduct, and conduct prejudicial to the best interest of the service.
• The Supreme Court imposed the following sanctions:
• Dismissal from the service with prejudice to reemployment in any branch of the government or its instrumentalities.
• Forfeiture of his retirement benefits, except accrued leave credits.

Issue:

• Whether Judge Marcial M. Deray’s inordinate delay in resolving the preliminary examination violated the accused’s constitutional right to a speedy trial and due process.
• Whether the loss, mismanagement, and failure to promptly transmit case records by the respondent constituted gross negligence and inefficiency in the discharge of his judicial and administrative functions.
• Whether the explanations provided by the respondent (involving extraneous negotiations and the misplaced records) constitute acceptable justifications for the delay, or whether they demonstrate a deliberate disregard of judicial duties.
• Whether the failure to comply with the Supreme Court’s directives, including not manifesting his willingness to submit the case for resolution, amounts to insubordination and warrants severe disciplinary measures.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)