FACTS:
Before this Court are two (2)
letter-complaints filed by complainant Ramir Mina. In the first complaint, Mina
charged Judge Rodolfo A. Gatdula of the Municipal Trial Court of Balanga, Bataan,
with Undue Delay in rendering a decision. In the second complaint, he
accused respondent of Rendering an Unjust Decision, Ignorance of the Law, and Manifest
Partiality. Both complaints sprung from Civil Case No. 1752, entitled
“Sps. Reynaldo Raul and Maria Clara Chico vs. Sps. Florencio and
Eliza Mina.”
On September 9, 1998, Mina
filed his first complaint, alleging that he is the attorney-in-fact of his
parents, the defendants in a case for Unlawful Detainer.
[Defendants] on August 16,
1995 received summons from respondent judge in relation to said case.
Complainant noted that said Order clearly stated that the case shall be
governed by the Rules on Summary Procedure which, to complainants[‘] belief,
should be decided within the period of sixty (60) days to ninety (90) days
only. The last hearing of the case was on June 19, 1996, both parties
having submitted their position papers, it took respondent judge two years to
render a decision on July 7, 1998.
Complainant took respondent’s
statement asking the parties to “give the court the chance to study the case”
as an indication that, after such study, he will allow evidence to prove the
spuriousness of the deed of donation upon which plaintiffs rely for their cause
of action. Respondent, however, never gave them the opportunity to do so but
instead, two years later, rendered a decision unfavorable to complainant.
ISSUE: 1. Whether or not respondent
Judge is guilty of gross dereliction of duty.
2. Whether or not respondent Judge is guilty of rendering unjust decision.
HELD:
1. YES.
Respondent’s delay in rendering
the decision in Civil Case No. 1752 is clearly violative of Rule 3.05 of the
Code of Judicial Ethics, which provides that “A judge shall dispose of the
court’s business promptly and decide cases within the required periods.” The
failure of a judge to decide a case within the prescribed period is inexcusable
and constitutes gross dereliction of duty.With
respect to cases falling under the Revised Rules on Summary Procedure in
particular, first level courts are only allowed thirty (30) days following the
receipt of the last affidavit and position paper, or the expiration of the
period for filing the same, within which to render judgment. Respondent’s
unreasonably long delay in the resolution of the case defeats the very purpose
for the Revised Rules on Summary Procedure, which was precisely enacted to
achieve an expeditious and inexpensive determination of cases. This Court has
consistently held that judges should be more conscientious in the discharge of
their duties, particularly the prompt resolution of cases covered by the Rule
on Summary Procedure, lest the rationale for its enactment be rendered
meaningless and inutile
2. NO.
From the foregoing, the Court
cannot conclude that respondent judge is guilty of the charges against him.
Notably, the judge’s decision was affirmed by the Regional Trial Court. Even
assuming that the decision of the judge is erroneous, his failure to correctly
interpret the law or to properly appreciate the evidence does not necessarily
render him administratively liable. To merit disciplinary sanction, the error
or mistake must be gross or patent, malicious, deliberate, or in bad faith. In
the absence of proof to the contrary, a defective or erroneous decision or
order is presumed to have been issued in good faith.
WHEREFORE, respondent Judge
Gatdula is found GUILTY of GROSS INEFFICIENCY on the first complaint and is
hereby ordered to pay a FINE of P5,000.00, with a warning that the same or
similar acts shall be dealt with more severely.
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