Corporate Managers and Consultants, Inc. v. Acosta
REITERATIONFacts
The Antecedents: Domingo G. Paguyo filed an ejectment case with damages against The Corporate Managers and Consultants, Inc. (defendant) with the Municipal Court of Makati. After filing its Answer, the defendant filed a Motion to Compel Plaintiff to Return Unused Rental, alleging it had advanced P44,500.00 for six months' rental, but vacated the premises after four months due to the lessor's violation of the lease agreement, entitling it to a refund for the two unused months. Procedural History: Plaintiff Paguyo filed an Opposition and Supplemental Opposition to the defendant's motion. The defendant filed a Reply to the Opposition. After the motion was submitted for resolution, respondent Judge Manuel B. Acosta issued an Order on April 21, 1981, denying the motion. The complainant charged the respondent judge with acting on the motion only after the lapse of more than eight months, far beyond the reglementary period of ninety (90) days required by the Rules of Court. The Petition: The complainant alleged that the respondent judge acted on the motion "after a long stretch of time, far beyond the reglementary period of ninety (90) days... required by the Rules of Court after the motion was submitted for resolution." The respondent judge averred that it was premature to act on the motion as evidence had not yet been introduced and the parties were negotiating an amicable settlement.
Issue(s)
Whether the respondent judge committed a dereliction of duty by failing to resolve the "Motion to Compel Plaintiff to Return Unused Rentals to Defendant" within the reglementary period of ninety (90) days.
Ruling
The Supreme Court found that the respondent judge resolved the complainant's motion far beyond the reglementary period of ninety days after the same had been submitted for resolution. The Court admonished and warned respondent Judge Manuel B. Acosta that a repetition of such infraction will be severely dealt with.
Ratio Decidendi
On Whether the respondent judge committed a dereliction of duty by failing to resolve the "Motion to Compel Plaintiff to Return Unused Rentals to Defendant" within the reglementary period of ninety (90) days: The Supreme Court held that it is clear that the respondent resolved the complainant's Motion far beyond the reglementary period of ninety days after the same had been submitted for resolution. This constituted the basis of the complaint against the respondent Judge, not that he wrongly resolved the said Motion. The Court emphasized that judges are required to act on motions submitted for resolution within the reglementary period prescribed by the Rules of Court. Failure to do so is considered a dereliction of duty. However, considering that the respondent judge had not committed the same dereliction before and that the resolution itself was not erroneous, the Court imposed a penalty of admonition and warning, stating that a repetition of such infraction would be severely dealt with. The Court's action reflects a balance between enforcing procedural rules and considering the circumstances of the case and the judge's record.
Main Doctrine
The Supreme Court reiterated that a judge's failure to resolve a motion within the prescribed ninety-day period constitutes a violation of the Rules of Court and amounts to a dereliction of duty. While the respondent judge in this case was admonished rather than severely penalized due to the absence of prior infractions and the fact that the resolution itself was not erroneous, the ruling emphasizes the importance of timely action by the judiciary.