Facts:

The case at hand is an administrative complaint filed by Danilo David S. Mariano against Judge Jose P. Nacional, stemming from an ejectment action docketed as Civil Case No. 12334. The events unfolded in the Municipal Circuit Trial Court of Camaligan-Gainza-Milaor, Camarines Sur. On September 3, 2004, Judge Nacional issued a pre-trial order requiring both parties to submit their position papers and affidavits of witnesses by September 30, 2004. The parties complied with this order. Subsequently, on December 28, 2004, the judge issued another order requiring the parties to submit memoranda in the form of a court decision, which they also complied with. However, the case was not decided until February 14, 2005, which was 136 days after the deadline mandated by law. Mariano contended that the issuance of the December 28 order violated the Revised Rules on Summary Procedure (RRSP), which prohibits such memoranda. He also argued that the delay in deciding the case constituted gros...

Facts:

1. Case Background: The case stemmed from an ejectment action (Civil Case No. 12334) filed by Danilo David S. Mariano against the City of Naga. The plaintiffs alleged that the City of Naga refused to vacate a parcel of land donated to it, claiming the donation was void due to non-compliance with conditions. The City of Naga countered that the donation remained valid.
2. Procedural Timeline:
   • On September 3, 2004, respondent Judge Jose P. Nacional issued a pre-trial order requiring the parties to file their position papers and affidavits by September 30, 2004. The parties complied.
   • On December 28, 2004, Judge Nacional issued another order requiring the parties to submit memoranda in the form of a court decision. The parties again complied.
   • The case was decided on February 14, 2005, 136 days after the 30-day reglementary period under the Revised Rules on Summary Procedure (RRSP).
3. Complaint: Mariano filed an administrative complaint against Judge Nacional for gross inefficiency, gross ignorance of the law, dereliction of duty, and violation of judicial conduct. He alleged that the December 28, 2004 order violated the RRSP’s prohibition on memoranda and that the delay in rendering judgment violated procedural rules.
4. Respondent’s Defense: Judge Nacional admitted exceeding the reglementary period but justified his actions by citing the complexity of the case, his heavy caseload, and the voluminous records. He also claimed the complaint was filed because the judgment was unfavorable to Mariano.
5. OCA Findings: The Office of the Court Administrator (OCA) found Judge Nacional guilty of violating basic procedure and the Code of Judicial Conduct. It noted that he had been previously admonished for similar offenses in Prado v. Judge Nacional. The OCA recommended a fine of P20,000 and a stern warning.

Issue:

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Ruling:

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Ratio:

1. Prohibition on Memoranda in Summary Proceedings: The RRSP explicitly prohibits the filing of memoranda in summary proceedings to ensure the expeditious and inexpensive resolution of cases. Judge Nacional’s order requiring memoranda violated this rule.
2. Mandatory Period for Rendering Judgment: The 30-day reglementary period for rendering judgment in ejectment cases is mandatory. Judges cannot unilaterally extend this period without a formal request to the Supreme Court. Judge Nacional’s delay of 136 days constituted gross inefficiency and gross ignorance of the law.
3. Judicial Competence and Diligence: Judges are required to maintain professional competence and diligence. Ignorance of basic procedural rules, especially those designed to expedite cases, is inexcusable.
4. Length of Service as a Factor: While length of service can sometimes mitigate penalties, it can also justify harsher sanctions if the judge’s actions demonstrate a pattern of incompetence or disregard for procedural rules.
5. Penalties for Judicial Misconduct: Gross ignorance of the law and procedure is classified as a serious charge under A.M. No. 01-8-10-SC, punishable by fines or suspension. Violations of judicial conduct and the Code of Professional Responsibility are also subject to fines and warnings.