Sordan v. De Guzman
REITERATIONFacts
The Antecedents: Complainant Albert R. Sordan was a plaintiff in an Unlawful Detainer case (Civil Case No. CV-157715) assigned to respondent Judge Rolando B. De Guzman. Sordan filed an Urgent Manifestation and Motion to Render Judgment By Reason of Failure to Answer on December 23, 1997, due to the defendant's failure to file an answer, as per Section 6 of the Rule on Summary Procedure. Procedural History: Sordan filed a Motion for Early Resolution on January 21, 1998, as the respondent Judge had allegedly failed to render a decision within the 30-day reglementary period. The complainant initiated the instant administrative case for the respondent Judge's alleged failure to promptly discharge his professional responsibility. The respondent Judge contended that the motion was defective as it was not set for hearing and lacked proper notice. He also claimed the case was not yet submitted for decision and that he opted not to decide it immediately due to other pending cases. He later stated a decision was rendered on December 14, 1998. The Petition: The complainant prayed for the dismissal and fining of the respondent Judge for his failure to conscientiously and promptly discharge his professional responsibility.
Issue(s)
Whether the respondent Judge failed to conscientiously and promptly discharge his professional responsibility by failing to render judgment within the reglementary period. Whether the respondent Judge's contention regarding the defective nature of the motion for judgment renders his inaction excusable.
Ruling
The Court found the recommendation of the Court Administrator to be well-taken and imposed a fine of P1,000.00 on the respondent Judge, with a warning against repetition.
Ratio Decidendi
On Issue 1: The respondent Judge failed to conscientiously and promptly discharge his professional responsibility. The Rule on Summary Procedure, specifically Section 6, mandates that if a defendant fails to answer the complaint, the court, motu proprio or upon motion, shall render judgment as warranted by the facts alleged in the complaint. This duty is explicit and does not allow for undue delay. The respondent Judge admitted to not rendering a decision for approximately six months after the complainant filed the motion, which is well beyond the 30-day reglementary period prescribed for cases under the Rule on Summary Procedure. The Supreme Court has consistently held that failure to observe this period subjects the judge to administrative sanctions, as the rule was enacted for the expeditious determination of cases. On Issue 2: The respondent Judge's contention that the motion was fatally defective and a mere scrap of paper is untenable. Section 6 of the Rule on Summary Procedure clearly states that the court shall render judgment motu proprio (on its own motion) or upon motion of the plaintiff. Therefore, even if the motion filed by the plaintiff were considered defective or not properly set for hearing, the respondent Judge had an independent duty to render judgment once the defendant failed to file an answer within the reglementary period. His failure to do so, regardless of the plaintiff's motion, constitutes a dereliction of duty. The fact that he eventually rendered a decision on December 14, 1998, does not absolve him from administrative liability for the delay that occurred prior to the filing of the administrative complaint.
Main Doctrine
A judge's failure to render judgment within the reglementary period, particularly in cases governed by the Rule on Summary Procedure, constitutes a violation of the mandate to conscientiously and promptly discharge professional responsibilities, subjecting the judge to administrative sanctions.