CASE BrieF 2017-0001

CASE: Trinidad Gamboa-Roces vs. Judge Ranhel A. Perez, Presiding Judge, MCTC, Enrique Magalona-Manapla, Negros Occidental [A.M. No. MTJ-16-1887]

PONENTE: Mendoza, J.:

SUBJECT:

  1. Legal Ethics:
    i. New Code of Judicial Conduct – Canon 6;
  2. 1987 Constitution:
    i. Section 15, Article VIII
  3. Rules on Summary Procedure:
    i. Period to Decide

“Judges should give full dedication to their primary and fundamental task of administering justice efficiently, in order to restore and maintain the people’s confidence in the courts.”

FACTS:        An administrative complaint was filed by Trinidad Gamboa-Roces charging Judge Ranhel A. Perez, Presiding Judge, Municipal Circuit Trial Court, E.B. Magalona Manapla, Negros Occidental, with for his failure to render judgment on the consolidated ejectment cases within the reglementary period as prescribed by law.

In his Comment, Judge Perez admitted that the cases were decided beyond the prescribed 30-day period and offered his deepest apologies, explaining that the delay was inadvertent and not intended to prejudice the plaintiffs. He explained that he was able to finish the final draft of his decision, but in his desire to have “a perfect decision,” he did not immediately forward the draft to his Clerk of Court as he would still polish it. He, however, got distracted with other issues and matters in the office.

He also asked for compassion and understanding, citing mainly his inexperience as a newly appointed judge as a reason therefor.

RULING:   Section 15, Article VIII of the 1987 Constitution requires the lower courts to decide or resolve cases or matters for decision or final resolution within three (3) months from date of submission.

In complaints for forcible entry and unlawful detainer as in this case, Section 10 of the Rules on Summary Procedure specifically requires that the complaint be resolved within thirty (30) days from receipt of the last affidavits and position papers. Without any order of extension granted by this Court, failure to decide even a single case within the required period constitutes gross inefficiency. 

In the same vein, Sections 2 and 5 of Canon 6 of the New Code of Judicial Conduct enjoin the judges to devote their professional activity to judicial duties and to perform them, including the delivery of reserved decisions, efficiently, fairly, and with reasonable promptness.

The Court has always reminded the judges to attend promptly to the business of the court and to decide cases within the required periods for the honor and integrity of the Judiciary is measured not only by the fairness and correctness of the decisions rendered, but also by the efficiency with which disputes are resolved.  Any delay in the disposition of cases erodes the public’s faith and confidence in the Judiciary.  Thus, judges should give full dedication to their primary and fundamental task of administering justice efficiently, in order to restore and maintain the people’s confidence in the courts.

In this case, the explanation given by Judge Perez was too flimsy. His being inexperienced as a newly appointed judge and his explanation that the delay was not intended to prejudice the plaintiffs are not persuasive because it is his duty to resolve the cases within the reglementary period as mandated by law and the rules. These excuses only show his lack of diligence in discharging administrative responsibilities and professional competence in court management. A judge is expected to keep his own listing of cases and to note therein the status of each case so that they may be acted upon accordingly and without delay. He must adopt a system of record management and organize his docket in order to monitor the flow of cases for a prompt and effective dispatch of business

The Fallo

WHEREFORE, finding respondent Judge Ranhel A. Perez, Municipal Circuit Trial Court, E.B. Magalona-Manapla, Negros Occidental, GUILTY of undue delay in rendering a decision, the Court hereby orders him to pay a FINE in the amount of TEN THOUSAND PESOS (₱10,000.00), with STERN WARNING that a repetition of the same or similar offense shall be dealt with more severely. SO ORDERED.

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THINGS DECIDED:

A)       Section 15, Article VIII of the 1987 Constitution requires the lower courts to decide or resolve cases or matters for decision or final resolution within three (3) months from date of submission.

B)       In complaints for forcible entry and unlawful detainer as in this case, Section 10 of the Rules on Summary Procedure specifically requires that the complaint be resolved within thirty (30) days from receipt of the last affidavits and position papers.

C)      Sections 2 and 5 of Canon 6 of the New Code of Judicial Conduct enjoin the judges to devote their professional activity to judicial duties and to perform them, including the delivery of reserved decisions, efficiently, fairly, and with reasonable promptness.

 ‘Stand by things decided’ ~ Stare Decisis


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