A.M. No. MTJ-99-1187 - Millare vs. Valera

Title: Millare vs. Valera

Case: A.M. No. MTJ-99-1187

Decision Date: Feb 15, 2000

Judge Valera fined P5,000 for delaying resolution of ejectment and unlawful detainer cases despite unresolved unpaid rentals, violating judicial duty.

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Case Digest (A.M. No. MTJ-99-1187)
Legal Reasoning Model

Facts:

Background of the Case

Complainant Pacifica A. Millare, represented by her son Paterno A. Millare, charged Judge Redentor B. Valera of the Municipal Trial Court (MTC) of Bangued, Abra, with gross negligence and inefficiency.

The charge arose from Judge Valera’s delay in disposing of two cases:

Civil Case No. 661 for ejectment.

Civil Case No. 961 for unlawful detainer.

Civil Case No. 661 was initially archived pending the resolution of Civil Case No. 1436 involving a contract of lease renewal filed by the Co spouses.

Upon the dismissal of Civil Case No. 1436, Case No. 661 was revived and joined with Case No. 961 for a consolidated trial, and the cases were assigned to Judge Esteban Guy.

Proceedings and Developments

On May 03, 1990, the spouses Co filed an “urgent motion to defer action on the cases with a motion to dismiss.”

On June 01, 1990, Judge Guy:

Denied the motion to defer the hearings and the motion to dismiss.

Issued an order noting that due to the defendants’ failure to secure a restraining order and to proceed with their trial, the evidence on their part was closed.

Submitted the cases for decision by declaring them “deemed submitted” for resolution.

Following an appeal by the defendants against Judge Guy’s order:

Judge Guy inhibited himself from further trying the cases.

Judge Redentor B. Valera assumed the case, and on August 22, 1990, he set the cases for hearing.

Subsequent Motions and Actions

The spouses Co moved to elevate the cases to the Regional Trial Court (RTC) of Abra on the ground that:

A notice of appeal had been filed by the defendants arguing that the actions had become “moot and academic” due to the premises having been vacated since May 01, 1987.

The amount of rent involved was beyond the jurisdiction of the MTC.

The plaintiff countered these claims by:

Arguing that the key to the premises had been improperly turned over to Atty. Demetrio V. Pre (uncle of the plaintiff’s counsel) instead of directly to her.

Claiming that the defendants had allowed Lilia Co and her family to occupy the premises between September 13, 1988, and January 1989.

On December 03, 1990, Judge Valera ordered that the key to the leased premises be handed over to either the plaintiff, her counsel, or through the court, though the key was later withdrawn by the plaintiff.

Multiple motions for an early resolution were subsequently filed:

On December 11, 1990.

On February 25, 1991.

On June 29, 1993.

Defense and Counter-Arguments

Respondent Judge Valera, in his answer, denied any inaction:

He contended that the cases were not yet submitted for a final decision.

Argued that the motions for early resolution were “mere scraps of paper” that failed to comply with applicable rules (Sections 4, 5, and 6, Rule 15, of the Rules of Court).

Maintained that the defendants’ voluntary vacating of the premises rendered the issues moot and academic.

Asserted that the matter of back rentals was beyond the jurisdiction of the MTC.

In her reply, the complainant argued that:

An order by Judge Guy on June 01, 1990, had already submitted the cases for decision.

The return of possession of the premises did not extinguish the claims for accrued rentals and damages.

Further, in her sur-rejoinder, the complainant maintained that:

Her counsel, Atty. Cielo Pre, did not receive the key.

The notice of appeal by the defendants was not perfected.

Evaluation by the Office of the Court Administrator (OCA)

After careful evaluation, the OCA recommended that:

Judge Valera be fined P10,000.00 for his failure to decide the cases within the prescribed period.

He be directed to render a decision on Civil Cases No. 661 and No. 961 with utmost dispatch.

The OCA’s report emphasized:

Only a final judgment on the merits is appealable, contrasting with interlocutory orders which do not dispose of the entire case.

The order by Judge Guy on June 01, 1990, closing evidence on the defendants was merely interlocutory.

A written final decision is required by the Rules of Court and the Constitution, stating facts and law clearly.

Vacating the premises did not automatically dispose of unresolved matters such as unpaid rentals and damages.

Court’s Findings and Decision

The Court found that:

The submission of the cases for decision by Judge Guy (June 01, 1990) was clear and had not been nullified by the pending appeal.

The claim that the unpaid rentals exceeded P20,000.00 was not a valid excuse for the delay.

Even considering jurisdictional rules for forcible entry and unlawful detainer cases, Judge Valera could have de-consolidated and dismissed the case lacking jurisdiction.

Accordingly, the Court:

Adopted the recommendation of the OCA with the modification to reduce the fine to P5,000.00 due to the circumstances.

Imposed a fine of P5,000.00 upon Judge Redentor B. Valera.

Directed him to decide the pending cases with utmost dispatch and to submit his decision within ten (10) days from its promulgation.

Issue:

Timely Disposition

Whether Judge Valera neglected his duty by failing to decide Civil Case No. 661 and No. 961 within the prescribed period.

Nature of the Orders and Their Appealability

Whether the order issued by Judge Guy (submitting the cases for decision) was final or interlocutory.

Whether the pending appeal or notice thereof could legally render the cases moot or academic.

Jurisdictional Concerns

Whether the issue of unpaid rentals exceeding P20,000.00 and the resulting jurisdictional deficiency could justify Judge Valera’s inaction.

Legal and Ethical Obligations

Whether the Code of Judicial Conduct and the Rules of Court mandate a prompt decision or disposition of cases, notwithstanding extraneous developments (e.g., vacation of the premises).

Ruling:

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Ratio:

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Doctrine:

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