De Jesus v. Obnamia, Jr.
REITERATIONFacts
The Antecedents: Complainant Atty. Clodualdo C. De Jesus, counsel for spouses Hilario and Felicitas Baldovino (defendants in an ejectment case), filed a complaint against respondent Judge Rodolfo D. Obnamia, Jr. for gross ignorance of the law, partiality, incompetence, and knowingly rendering an unjust judgment. The original ejectment case involved a lease agreement for two parcels of land where defendants constructed a movie house. The plaintiffs claimed the lease expired due to defendants' failure to notify them of their intention to renew. On December 5, 1994, Judge Nantes ordered the defendants to vacate 246 square meters of land, pay P4,000.00 monthly rental, and pay P10,000.00 attorney's fees. Judge Nantes later ordered the execution of the decision. Defendants' petition for certiorari in the RTC and Court of Appeals were dismissed, though the Court of Appeals modified the order to vacate to 220 square meters and allowed the movie house to reopen. Procedural History: Plaintiffs moved for a writ of demolition, alleging a portion of the movie house remained on the subject premises and was in danger of collapsing. Judge Nantes denied this on December 22, 1995. Plaintiffs moved for reconsideration, which was opposed by defendants. Meanwhile, plaintiffs also moved for an alias writ of execution to evict defendants. Respondent Judge Obnamia, Jr. took over the MCTC on July 14, 1997. He heard the motion for alias writ of execution on August 6, 1997, the same day defendants' counsel received the motion, thus defendants were not represented. On August 14, 1997, he granted the alias writ of execution. On September 25, 1997, he granted plaintiffs 15 days to file supplemental pleadings regarding their motion for reconsideration of the denial of the writ of demolition. On October 23, 1997, he granted the motion for reconsideration for a writ of demolition, ordering the demolition of the structure on 246 square meters within one month. He also denied defendants' motion for reconsideration of the alias writ of execution. Defendants filed a notice of appeal, which respondent judge denied on November 13, 1997, and subsequently denied their motion for reconsideration on November 28, 1997, stating the resolution was not appealable. The Petition: Complainant filed a petition for certiorari and mandamus and the present administrative case, alleging respondent judge amended Judge Nantes' order, contravened the Court of Appeals' decision, acted with gross ignorance of the law, incompetence, and knowingly rendered an unjust judgment. Specific charges included granting extensions for old motions, denying due course to the notice of appeal, and hearing the motion for alias writ of execution without proper notice.
Issue(s)
Whether respondent judge committed gross ignorance of the law, partiality, incompetence, and knowingly rendered an unjust judgment. Whether respondent judge erred in granting plaintiffs an additional fifteen (15) days to supplement their motion for reconsideration of the denial of their motion for a writ of demolition. Whether respondent judge erred in hearing the plaintiffs' motion for an alias writ of execution on August 6, 1997, without the required three days prior notice to the defendants. Whether respondent judge erred in denying due course to the defendants' notice of appeal from the resolution of October 23, 1997.
Ruling
The Supreme Court ordered respondent Judge Rodolfo D. Obnamia, Jr. to pay a FINE in the amount of THREE THOUSAND PESOS (P3,000.00) with a WARNING that a repetition of the same or similar acts will be dealt with more severely. The case was dismissed with regard to the other charges.
Ratio Decidendi
On the overall charges of gross ignorance of the law, partiality, incompetence, and knowingly rendering an unjust judgment: While the Court found censurable conduct regarding the violation of the three-day notice rule, it did not find sufficient grounds to sustain the more serious charges of gross ignorance of the law, incompetence, or knowingly rendering an unjust judgment. The Court noted that the respondent judge claimed unawareness of the Court of Appeals' decisions, which, if true, would mitigate the severity of the offense, though his subsequent actions were still subject to scrutiny. The Court ultimately imposed a fine for the procedural lapse. On the charge of granting plaintiffs an additional fifteen (15) days to supplement their motion for reconsideration: The Court found this allegation to be without merit. Respondent judge took over the case as acting presiding judge and, to familiarize himself with the pending incidents, directed both parties to file supplemental pleadings. The defendants did not file any, while the plaintiffs requested and were granted an extension. Complainant neither opposed the motion for extension nor sought reconsideration, thus failing to establish partiality. On the charge of hearing the plaintiffs' motion for an alias writ of execution on August 6, 1997, without three days prior notice: The Court found this contention to have merit. While generally, no prior notice or hearing is required for motions for execution of final and executory decisions, the circumstances here made it necessary. The Court of Appeals had modified the MCTC decision, limiting the area for ejectment. Respondent judge ordered execution for the original area, claiming the appellate court's rulings were not in the records. However, these rulings were later brought to his attention. Since the execution was a contentious matter due to the modification, respondent judge's failure to ensure compliance with the three-day notice rule for the hearing constituted censurable conduct. On the charge of denying due course to defendants' notice of appeal: The Court deemed it premature to rule on this issue as it was pending review in a separate petition for certiorari before the RTC. Therefore, no ruling was made on this specific charge within the administrative case.
Main Doctrine
A judge who fails to observe the three-day notice rule for hearings on motions, especially when the execution of a decision has become a contentious matter due to modifications by appellate courts, commits censurable conduct constituting a violation of procedural rules.