Facts:

The case involves Oscar C. Fernandez as the complainant and Judge Lilia C. Espaaol, the presiding judge of the Municipal Trial Court in Cities of Dagupan City, as the respondent. The events leading to the complaint began with a decision rendered on January 3, 1996, by Judge Jules A. Mejia, which favored Fernandez in a complaint for unlawful detainer against a defendant who was ordered to vacate the property and pay rentals, damages, and attorney's fees. Following this decision, the defendant filed a notice of appeal but failed to post a supersedeas bond or pay the monthly rentals. Consequently, Fernandez filed a motion for execution on March 21, 1996. Respondent Judge Espaaol, acting as the presiding judge after Judge Mejia's retirement, scheduled a hearing for April 15, 1996. During this hearing, despite Fernandez's objections, Judge Espaaol allowed the defendant ten days to submit a memorandum and granted Fernandez five days to file a reply. The defendant did no...

Facts:

Background of the Case

• Complainant, Oscar C. Fernandez, filed a complaint for unlawful detainer in the Municipal Trial Court in Cities (MTCC) of Dagupan City, Branch 2.
• On January 3, 1996, Judge Jules A. Mejia rendered a decision in favor of the complainant, ordering the defendant to vacate the property and pay rentals, damages, and attorney’s fees.
• The defendant filed a notice of appeal but failed to post a supersedeas bond or pay the monthly rentals.

Motion for Execution

• Complainant filed a motion for execution due to the defendant’s failure to comply with the bond and rental payment requirements.
• On March 21, 1996, respondent Judge Lilia C. España, acting as presiding judge in place of the retired Judge Mejia, set the motion for hearing on April 15, 1996.
• During the hearing, respondent judge allowed the defendant to submit a memorandum within 10 days and the complainant to file a reply within 5 days. No memorandum was filed by the defendant, but the complainant submitted a reply memorandum.

Issuance and Reconsideration of Writ of Execution

• On May 15, 1996, respondent judge granted the motion for execution and ordered the issuance of a writ of execution.
• The defendant filed a motion for reconsideration, claiming that the complainant’s brothers, who were co-owners of the property, had renewed the lease contract. The defendant attached an unsworn affidavit from the alleged co-owners stating they did not authorize the complaint and consented to the defendant’s continued stay.
• Complainant moved to expunge the motion for reconsideration, arguing it was prohibited under the Rules on Summary Procedure and contained misleading statements.

Respondent Judge’s Actions

• On June 27, 1996, respondent judge granted the defendant’s motion for reconsideration, deferred the issuance of the writ of execution, and forwarded the case records to the Regional Trial Court (RTC) for assessment of fees.
• Complainant alleged that the appellate docket fee was paid six months after the appeal period had expired.

Respondent Judge’s Defense

• Respondent judge claimed she granted the motion for reconsideration due to a supervening event (the alleged renewal of the lease by co-owners) and accused the complainant of pressuring her to rule in his favor.
• She also alleged that the complainant, a former RTC judge, frequently visited her chambers unannounced and discussed the merits of the case.

Office of the Court Administrator’s Findings

• The Office of the Court Administrator found the allegations in the complaint to be true and recommended that respondent judge be fined P10,000 with a warning.

Issue:

• (Unlock)

Ruling:

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Ratio:

1. Ignorance of the Law: Respondent judge failed to apply the Rules on Summary Procedure correctly. Ejectment cases are summary in nature, and the judgment is immediately executory unless the defendant posts a supersedeas bond and pays current rentals. Respondent judge should not have entertained the motion for reconsideration, which was prohibited under the rules.
2. Supervening Event: The alleged renewal of the lease by co-owners was not a valid supervening event because the complainant, as the appointed administrator, had sole authority to act on behalf of the estate at the time.
3. Lack of Malice: While respondent judge erred, there was no evidence of malice, bad faith, or deliberate intent to cause undue injury. Thus, a lower penalty was deemed appropriate.
4. Duty of Judges: Judges must be diligent in studying the records and applying the law correctly, especially in summary proceedings like ejectment cases.