Title
Cabahug vs. Dacanay
Case
A.M. No. MTJ-03-1480
Decision Date
Sep 10, 2003
Judge Dacanay delayed resolving a motion for 231 days, exceeding the 90-day limit, leading to a fine for gross inefficiency despite claims of complainant's non-coordination.

Case Summary (A.M. No. MTJ-03-1480)

Relevant Dates and Proceedings

The timeline of significant events begins with the favorable judgment for Cirilo Cabahug, affirmed by the Regional Trial Court and later by the Court of Appeals, with the decision becoming final on February 17, 2000. Following the issuance of a writ of execution on November 3, 2000, the sheriff executed the judgment and ejected the defendant from the property. However, issues arose when Rosalinda Cabahug, the wife of the defendant, encroached upon the property again, prompting Trinidad to file a contempt motion on July 24, 2001. The Municipal Trial Court denied this motion on August 24, 2001. Trinidad filed a motion for reconsideration on September 19, 2001, which remained unresolved for an extended period, leading to the administrative complaint.

Allegations Against the Respondent

The complainant alleged undue delay by Judge Dacanay in resolving her motion for reconsideration filed in September 2001. Judging from her affidavit-complaint dated June 3, 2002, Trinidad expressed frustration over the inaction on her motion and claimed that even after her inquiry in December 2001, the judge failed to address the motion in a timely manner. The judge, in his comment, indicated that the complainant's actions, specifically her choice of counsel and subsequent motion to withdraw, contributed to the delay.

Judicial Administration Findings

The Office of the Court Administrator (OCA), through Court Administrator Presbitero J. Velasco, Jr., conducted an investigation and submitted a report finding Judge Dacanay guilty of gross inefficiency. The OCA pointed out the judge's failure to resolve the motion for reconsideration within the mandated 90-day period, which constituted gross inefficiency under judicial standards. The report noted that 231 days passed before the motion was addressed, and the judge's reliance on the complainant’s actions was deemed insufficient to justify the delay.

Conclusion and Penalty

Upon review, the Supreme Court

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