Title
Young vs. De Guzman
Case
A.M. No. RTJ-96-1365
Decision Date
Feb 18, 1999
Judge De Guzman faced allegations of unreasonable delay in resolving a complex property case and granting attorney's fees hastily. The Supreme Court dismissed the complaint, citing no bad faith, case complexity, and his illness, ordering the release of withheld retirement benefits.
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Case Summary (A.M. No. RTJ-96-1365)

Administrative Case Overview

  • Robert G. Young filed an administrative complaint against Judge Pastor V. De Guzman for unreasonable delay in the disposition of Civil Case No. 873-R.
  • The case involved the recovery of unpaid rentals from store space lessees and accounting for all rentals due from a condominium property.
  • The Office of the Court Administrator (OCA) evaluated the case and found that the judge failed to comply with Administrative Circular No. 4, recommending a fine of P5,000.00.
  • The Supreme Court ultimately dismissed the complaint, finding no evidence of bad faith or malice on the part of the judge.

Judicial Responsibilities and Due Process

  • Judges are mandated to resolve cases promptly, as stipulated by the Rules of Court and the Code of Judicial Conduct.
  • However, judges must not compromise due process for the sake of expediency.
  • The respondent judge believed that the issues could only be resolved after all parties were fully heard, emphasizing the need for a thorough examination of the case.
  • The judge's order on December 20, 1990, indicated that the entitlement to rental deposits required a prior resolution of ownership issues.

Case Background and Procedural History

  • The complaint arose from a verified letter dated March 26, 1996, by Robert G. Young, President of Banawe Realty Development Corporation.
  • The case involved multiple parties, including La Commercial Company and China Banking Corporation, which were substituted during the proceedings.
  • An earthquake in July 1990 destroyed the condominium, leading to a joint motion to dismiss the case, which remained unresolved.
  • The complainant alleged that the judge acted with undue haste in granting attorney's fees to Atty. Helenea M. Dauz while neglecting the main case.

Judge's Defense and Case Complexity

  • Judge De Guzman countered that the case was complex, involving issues of ownership and possession, rather than a simple rental recovery.
  • He clarified that the substitution of parties was misrepresented and that the case's complexity contributed to the delay.
  • The judge attributed the delay to the parties' motions and pleadings, as well as his own health issues that required a prolonged leave of absence.
  • He maintained that the motion for attorney's fees was resolved only after Banawe Realty failed to file any opposition.

Evaluation by the Office of the Court Administrator

  • The OCA found that the judge did not comply with the directive to expedite older cases and recommended a fine.
  • The Supreme Court required both parties to indicate their willingness to submit the case for resolution base...continue reading

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