Title
Bangco vs. Gatdula
Case
A.M. No. MTJ-00-1297
Decision Date
Mar 7, 2001
Judge Gatdula delayed a forcible entry case by failing to act on motions and render a decision for over two years, violating judicial conduct rules; fined P15,000 by the Supreme Court.
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Case Digest (A.M. No. MTJ-00-1297)

Facts:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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:

  1. Whether respondent judge is guilty of undue delay in rendering a decision or order in Civil Case No. 1761.
  2. 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:

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