Case Digest (A.M. No. MTJ-00-1297)
Facts:
The case involves Josefina Bangco, represented by her brother and attorney-in-fact, Oscar Bangco, as the complainant against Judge Rodolfo S. Gatdula of the Municipal Trial Court (MTC) of Balanga, Bataan. The complaint was filed on June 11, 1997, alleging undue delay in the resolution of Civil Case No. 1761, which concerned a forcible entry dispute against spouses Juanito Rodil and Leviminda Tajonera-Rodil. The complainant claimed that Judge Gatdula failed to act on the case for five months after he verbally declared it submitted for decision and for nearly two months after receiving a motion for judgment on the pleadings. Despite filing three motions to declare the defendants in default, the judge did not resolve these motions, instead informing the complainant's counsel that such motions were prohibited under the Rule on Summary Procedure. On September 30, 1996, the complainant received an order from the judge requiring her to submit necessary pleadings within ten days,...
Case Digest (A.M. No. MTJ-00-1297)
Facts:
Parties Involved:
- Complainant: Josefina Bangco, represented by her attorney-in-fact, Oscar Bangco.
- Respondent: Judge Rodolfo S. Gatdula of the Municipal Trial Court (MTC) of Balanga, Bataan.
Nature of the Case:
- The case involves Civil Case No. 1761, a forcible entry case filed by Josefina Bangco against spouses Juanito Rodil and Leviminda Tajonera-Rodil.
Timeline of Events:
- November 13, 1995: The forcible entry case was filed.
- November 15, 1995: Summons were served on the defendants by substituted service.
- January 9, 1996, March 23, 1996, and June 14, 1996: Complainant filed three separate motions to declare defendants in default, but these were not acted upon by the respondent judge.
- October 7, 1996: Complainant filed a motion for judgment on the pleadings, which was also not resolved.
- February 7, 1997: Complainant filed a motion to inhibit respondent judge and transfer the case to another judge, but this motion remained unacted upon.
- June 26, 1996: Respondent judge verbally declared the case submitted for decision, but no decision was rendered for five months.
- January 7, 1997: Respondent judge finally rendered a decision on the case.
Complainant’s Allegations:
- Respondent judge deliberately neglected to act on the case for five months after declaring it submitted for decision.
- Respondent judge failed to resolve multiple motions filed by the complainant, including motions to declare defendants in default and a motion for judgment on the pleadings.
- Complainant sensed partiality and filed a motion to inhibit respondent judge, which was also ignored.
Respondent Judge’s Defense:
- Respondent judge claimed that the delay was due to complainant’s expressed willingness to settle the case amicably.
- He alleged that complainant requested him to hold the resolution of the case pending negotiations with the defendants.
- He was surprised when he received the administrative complaint, as he believed the case had been settled.
Investigation Findings:
- Executive Judge Vianzon found that respondent judge failed to act on multiple motions and delayed the resolution of the case for over two years.
- The Office of the Court Administrator (OCA) found respondent judge liable for delaying the proceedings and recommended a fine of P20,000.
Issue:
- Whether respondent judge is guilty of undue delay in rendering a decision or order in Civil Case No. 1761.
- Whether respondent judge’s failure to resolve motions and decide the case within the reglementary period constitutes a violation of judicial conduct rules.
Ruling:
The Supreme Court found respondent Judge Rodolfo S. Gatdula guilty of undue delay in rendering a decision or order. The Court imposed a fine of P15,000.00, with a stern warning that repetition of the same act would be dealt with more severely.
Ratio:
- (Unlock)