Case Summary (A.M. No. MTJ-98-1150)

Complaint Against Respondent Judge

The complaint against the respondent judge, Lilia C. Espaol, alleges gross ignorance of the law, the rendering of an unjust interlocutory order, and a violation of Republic Act No. 3019, specifically Section 3(e), which pertains to causing undue injury to a party litigant. The complainant, Oscar C. Fernandez, was the plaintiff in an unlawful detainer case in the Municipal Trial Court in Dagupan City, where a favorable decision was rendered in his favor on January 3, 1996. The defendant's failure to post a supersedeas bond and pay monthly rentals led the complainant to file a motion for execution.

• Allegations include gross ignorance of law and unjust orders.
• Complainant is the plaintiff in an unlawful detainer case.
• Favorable decision was rendered on January 3, 1996.
• Defendant failed to post a supersedeas bond and pay rentals.

Procedural Developments

On March 21, 1996, the respondent judge scheduled a hearing for the motion for execution. During the hearing, despite the complainant's objections, the judge allowed the defendant additional time to submit a memorandum and granted the complainant time to file a reply. The defendant did not submit the memorandum, while the complainant filed a reply. On May 15, 1996, the judge granted the motion for execution, but the defendant subsequently filed a motion for reconsideration, claiming that the complainant's co-owners had renewed the lease.

• Hearing for the motion for execution was scheduled.
• Respondent judge allowed additional time for the defendant to submit a memorandum.
• The defendant failed to submit the memorandum.
• The judge granted the motion for execution on May 15, 1996.

Motion for Reconsideration and Subsequent Orders

The defendant's motion for reconsideration included an unsworn affidavit from the co-owners, asserting that they did not authorize the complaint and consented to the defendant's continued occupancy. The complainant moved to expunge this motion, arguing it was unauthorized under the Rules on Summary Procedure. On June 27, 1996, the respondent judge granted the motion for reconsideration, allowing the defendant's appeal and deferring the issuance of the writ of execution.

• Defendant's motion for reconsideration included an unsworn affidavit.
• Complainant sought to expunge the motion for reconsideration.
• Respondent judge granted the motion for reconsideration on June 27, 1996.

Justification for the Judge's Actions

In her defense, the respondent judge claimed that her decision was based on a supervening event—the renewal of the lease by the co-owners—which justified the stay of execution. She accused the complainant of pressuring her to rule in his favor and claimed that the complaint was filed by a disgruntled litigant. The judge also mentioned that the complainant had engaged her in lengthy discussions about the case, which she felt obligated to entertain due to his previous position as a judge.

• Respondent judge cited a supervening event as justification for her decision.
• She accused the complainant of pressuring her and being a disgruntled litigant.
• The judge felt obligated to engage in discussions with the complainant.

Findings of the Office of the Court Administrator

The Office of the Court Administrator evaluated the complaint and found the allegations to be true. Deputy Court Administrator Reynaldo Suarez recommended that the respondent judge be found administratively liable and fined P10,000, with a warning regarding future conduct. The recommendation was based on the judge's failure to adhere to the Rules on Summary Procedure, particularly regarding the immediate executory nature of judgments in ejectment cases.

• The Office of the Court Administrator found the allegations true.
• A recommendation for a P10,000 fine was made.
• The judge failed to follow the Rules on Summary Procedure.

Legal Principles and Errors

The court noted that the Rules on Summary Procedure apply to the main action and not to incidents occurring afterward. The respondent judge should have recognized that the judgment in an unlawful detainer case is immediately executory unless spe...continue reading