Facts:

This case, identified as A.M. No. MTJ-00-1297 and decided on March 7, 2002, involves complainant Josefina Bangco, represented by her brother and attorney-in-fact, Oscar Bangco, and respondent Judge Rodolfo S. Gatdula of the Municipal Trial Court (MTC) in Balanga, Bataan. The administrative complaint arose from an alleged delay in the resolution of Civil Case No. 1761, wherein Josefina Bangco sued Spouses Juanito Rodil and Leviminda Tajonera-Rodil for forcible entry. The complaint was lodged via a verified letter to the Court Administrator on June 11, 1997. Bangco accused Judge Gatdula of neglecting to act on her case for five months after verbally declaring it ready for decision and for nearly two months following the reception of her motion for judgment on the pleadings. Despite her multiple motions to declare the defendants in default, the judge had not taken action, leading to an impression of bias. In response, Judge Gatdula noted that the delay was due to the complainant

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Facts:

Background of the Case

• Complainant: Josefina Bangco, a resident of Chicago, Illinois, represented by her attorney-in-fact, Oscar Bangco.
• Subject Matter: Delayed resolution of Civil Case No. 1761 involving a forcible entry claim against Spouses Juanito Rodil and Leviminda Tajonera-Rodil.
• Filing and Service:
• The case was filed on November 13, 1995, with summons served on the defendants by substituted service on November 15, 1995.
• Complainant secured substituted service on the defendants, who then failed to file their required answer.

Allegations and Proceedings

• Nature of the Complaint:
• Complainant alleged that Judge Rodolfo S. Gatdula deliberately delayed disposing of the case.
• It was claimed that the judge neglected to resolve or act on multiple motions filed by the complainant.
• Sequence of Filings by the Complainant:
• Complainant’s initial motion for judgment on the pleadings was filed on October 17, 1996, after an earlier order dated September 18, 1996 required submission of necessary pleadings within ten days.
• Prior to this, three separate motions for the declaration of defendants in default were filed but went unacted upon by the judge.
• Sensing impartiality due to the judge’s inaction, the complainant also filed a motion to inhibit and transfer the case to another judge, which likewise remained unacted upon.

Judge’s Response and Other Developments

• Judge Gatdula’s Defense:
• The judge argued that the delay stemmed from the complainant’s expressed desire to settle the case amicably, essentially putting a hold on further proceedings.
• He noted that while preparing an order regarding the motion, an accidental encounter with defendant Leviminda Rodil revealed that the parties had settled, prompting a motion to withdraw the complaint.
• Administrative Involvement:
• The complaint triggered an administrative investigation initiated by a verified letter-complaint dated June 11, 1997, addressed to the Court Administrator.
• The Office of the Court Administrator (OCA) and Executive Judge Vianzon of the RTC of Bataan at Balanga investigated the matter.
• Executive Judge Vianzon’s findings highlighted that, despite multiple motions and a declared case submission, no decision was rendered within the prescribed period.
• The investigation documented that the case was only finally decided on January 7, 1997, signifying a delay of more than two years beyond the timeline required by law.
• Prior Disciplinary Record:
• It was also noted in the records that Judge Gatdula had a previous fine of P10,000.00 for oppression and acts unbecoming of a judge.
• Additionally, there were three pending administrative cases against him involving charges such as ignorance of the law, serious misconduct, and further delays in rendering decisions.

Investigation Recommendations and Findings

• Based on the report of Executive Judge Vianzon, a recommendation was made reminding the judge to decide cases promptly, as mandated by the Rules of Court.
• The OCA, after a thorough investigation, found Judge Gatdula liable for undue delay and recommended imposing a fine of P20,000.00 with a stern warning regarding future conduct.
• The Court later modified the sanction by imposing a fine of P15,000.00 on the judge.

Issue:

• Whether Judge Gatdula committed the administrative offense of undue delay by failing to render a timely decision in Civil Case No. 1761.
• Whether the judge’s justification—that the delay was due to the complainant’s willingness to settle the case amicably—serves as a valid excuse for his inaction.
• Whether the prior disciplinary history and the investigative findings sufficiently substantiate imposing a sanction on the judge for non-compliance with the reglementary period as provided under the Rules of Court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)