GAMBOA-ROCES vs. JUDGE PEREZ

TRINIDAD GAMBOA-ROCES, Complainant  vs. JUDGE RANHEL A. PEREZ, Presiding Judge, Municipal Circuit Trial Court, Enrique Magalona-Manapla, Negros Occidental, Respondent

A.M. No. MTJ-16-1887

January 9, 2017

Facts:

The case is about an administrative complaint filed by Trinidad Gamboa-Roces (complainant) charging Judge Ranhel A. Perez (Judge Perez), Presiding Judge, Municipal Circuit Trial Court, E.B. MagalonaManapla, Negros Occidental (MCTC), with gross ignorance of the law for his failure to render judgment on the consolidated ejectment cases, docketed as Civil Case Nos. 451-M and 452-M, within the reglementary period as prescribed by law.

In her complaint, denominated as Petition, dated November 17, 2015, complainant claimed that she was one of the plaintiffs in Civil Case Nos. 451-M and 452-M for unlawful detainer and damages. After the mediation proceedings and the Judicial Dispute Resolution proceedings failed in Civil Case No. 451-M, it was referred back to the MCTC for trial and was set for preliminary conference. As a new judge was soon to be assigned in the MCTC, the preliminary conference was reset to January 10, 2014, by Judge Evelyn D. Arsenio, the then acting Presiding Judge.

Complainant stated that when Judge Perez was appointed and assumed office, her counsel filed two (2) separate motions for his inhibition in the two cases on the ground that she was previously involved in a legal confrontation with Judge Perez himself when he was representing his parents. Her motions, however, were denied in separate orders. Thereafter, Civil Case Nos. 451- M and 452-M were consolidated in the Order, dated March 11, 2014. After the preliminary conference for the two cases was held, the parties were then required to file their respective position papers. Thereafter, Judge Perez issued the Order, dated November 21, 2014, submitting the cases for resolution. With this, complainant claimed that despite the lapse of more than ten (10) months, Judge Perez failed to decide the cases in violation of the 30-day reglementary period within which to decide an ejectment case.

Judge Perez on the other hand, admitted that Civil Case Nos. 451-M and 452-M 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 on December 1, 2014, 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 its decision. He, however, got distracted with other issues and matters in the office.

The Office of the Court Administrator (OCA) through its Report, dated September 7, 2016, recommended that the complaint be re-docketed as a regular administrative matter and that "Judge Perez be found GUILTY of undue delay in rendering a decision or order and be admonished to be more mindful in the performance of his duties particularly in the prompt disposition of cases pending and/or submitted for decision/resolution before his court.

Issue:

Whether or not the Respondent as the Presiding Judge is guilty of undue delay of rendering a decision within the reglementary period as prescribed by law.

Ruling: 

Yes, the Respondent as the Presiding Judge is guilty of undue delay of rendering a decision within the reglementary period as prescribed by law..The Supreme Court cited Section 15, Article VIII of the 1987 Constitution which 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. Moreover, 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. This obligation to render decision promptly is further emphasized in Administrative Circular No. 3-99 which reminds all judges to meticulously observe the periods prescribed by the Constitution for deciding cases because failure to comply with the prescribed period transgresses the parties' constitutional right to speedy disposition of their cases.

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.

The explanation given by Judge Perez of his being inexperienced as a newly appointed judge was too flimsy. The excuses only show his lack of diligence in discharging administrative responsibilities and professional competence in court management wherein 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 and 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.