Facts:

In the case of Custodio Escabillas vs. Hon. Luis D. Martinez, the complainant, Custodio Escabillas, filed a sworn letter complaint on October 5, 1972, against the respondent, Municipal Judge Luis D. Martinez of Hagonoy, Davao del Sur. Escabillas accused the judge of gross misconduct and ignorance of the law for allegedly extending the terms of a lease contract contrary to a prior court ruling, as well as for unreasonable delay in deciding Civil Case No. 261, which he claimed was not resolved within the 90-day period mandated by law. The background of the case involves Escabillas purchasing two parcels of land from spouses Pedro N. de los Reyes and Beatriz Torrecampo on January 7, 1970, with Transfer Certificates of Title issued in his name. Lot A, covered by TCT No. T-3539, had an annotation of a lease contract from 1963 between the former owners and the Bangayans. A previous court ruling in Civil Case No. 4939, dated May 15, 1969, upheld the right of the former owners to rep...

Facts:

1. Purchase of Land and Lease Contract:

   • Complainant Custodio Escabillas purchased two parcels of land (Lots A and B) from spouses Pedro N. de los Reyes and Beatriz Torrecampo on January 7, 1970.
   • Transfer Certificates of Title (TCTs) were issued in Escabillas' name. Lot A had an annotation of a lease contract between the former owners and the Bangayans, dated 1963.

2. Court of First Instance Decision:

   • In Civil Case No. 4939, the Court of First Instance of Davao del Sur ruled on May 15, 1969, that the Reyes spouses had the right to repurchase the lots from the Bangayans. The court also directed that the unexpired period of the lease contract on Lot A be respected.

3. Motion for Clarification and Cancellation of Lease:

   • On April 30, 1970, Escabillas and the Reyes spouses filed a motion to clarify the judgment regarding the lease's expiry date and to cancel the lease annotation on Lot A.
   • The Court of First Instance, in its Order of May 20, 1970, declared that the lease expired on April 15, 1970, and authorized the cancellation of the lease annotation.

4. Supreme Court Proceedings:

   • The Bangayans appealed the May 20, 1970, Order to the Supreme Court, but their petition for review on certiorari was denied on August 3, 1971, and again on October 5, 1971.

5. Unlawful Detainer Case:

   • Escabillas filed an unlawful detainer case against the Bangayans in the Municipal Court of Hagonoy, Davao del Sur, which was dismissed by respondent Judge Luis D. Martinez for being premature.
   • Escabillas later filed Civil Case No. 261 for unlawful detainer, which was decided by Judge Martinez on August 31, 1972. The decision ordered the Bangayans to surrender Lot A to Escabillas after receiving P9,000.00, and to pay attorney's fees and representation expenses.

6. Administrative Complaint:

   • Escabillas filed an administrative complaint against Judge Martinez, alleging gross misconduct, gross ignorance of the law, and unreasonable delay in deciding Civil Case No. 261.

Issue:

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Ruling:

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Ratio:

1. Finality of Court Orders:

   • A judge has no authority to alter or amend a final order of a higher court. Judge Martinez correctly refused to interfere with the lease contract's terms, as the Court of First Instance's order had already become final and was affirmed by the Supreme Court.

2. Prompt Disposition of Cases:

   • Judges are mandated to decide cases within 90 days from submission, as provided under Section 5 of the Judiciary Act of 1948. Delay in the administration of justice undermines public confidence in the judiciary and defeats the purpose of a speedy resolution of cases.

3. Sanction for Delay:

   • While the charge of gross misconduct and ignorance of the law was dismissed, Judge Martinez was reprimanded for violating the 90-day rule. He was enjoined to strictly comply with the Judiciary Act in the future.