Guevarra v. Maceda
REITERATIONFacts
The Antecedents: Complainants, Spouses Rodolfo and Violeta Guevarra, filed a civil case against Spouses Mariolito and Corazon Lano, et al. The Lano spouses filed a Motion to Dismiss and a Motion for Extension of Time to File Responsive Pleading. The respondent judge denied the Motion to Dismiss. Procedural History: Complainants filed a Motion to Declare Defendants in Default after the Lano spouses failed to file a responsive pleading. The Lano spouses subsequently filed a Motion to Admit Answer, which complainants opposed. Complainants then filed several motions seeking the resolution of their Motion to Declare Defendants in Default, averring that the respondent judge failed to rule on it despite the lapse of the 90-day reglementary period. The respondent judge claimed that the 90-day period should be reckoned from the filing of the Affidavit of Merit by the Lano spouses, which was the last pleading concerning the two motions, and that he resolved the motions on May 13, 2002, within the period which would have lapsed on May 15, 2002. The Petition: Complainants charged the respondent judge with gross inefficiency for allegedly failing to resolve their Motion to Declare Defendants in Default within the reglementary period.
Issue(s)
Whether the respondent judge was guilty of gross inefficiency for failing to resolve the complainants' Motion to Declare Defendants in Default within the 90-day reglementary period. Whether the filing of the administrative complaint was premature.
Ruling
The charge of gross inefficiency against the respondent judge is dismissed. The administrative complaint was found to be premature.
Ratio Decidendi
On the issue of gross inefficiency: The Court ruled that the respondent judge was not guilty of gross inefficiency. The complainants erroneously counted the 90-day reglementary period from the filing of their Motion to Declare Defendants in Default on January 4, 2002. The Court clarified that the reglementary period for resolving motions should be reckoned from the date of the filing of the last pleading that completes the submission of the matter for resolution. In this case, the default motion was deemed submitted for resolution only upon receipt by the RTC of the Affidavit of Merit on February 14, 2002. Therefore, the respondent judge had until May 15, 2002, within which to resolve the subject incidents. Since the respondent judge issued an Order resolving the motions on May 13, 2002, which was before the reglementary period lapsed, there was no violation of the 90-day period. On the issue of premature filing: Consequently, the filing of the administrative complaint on April 29, 2002, was premature. The Court emphasized its resolve not to tolerate acts that erode faith in the judiciary but also to protect the innocent from baseless accusations.
Main Doctrine
A judge is not liable for gross inefficiency for failing to resolve a motion within the 90-day reglementary period if the period has not yet lapsed, considering that the reckoning of the period should be from the filing of the last pleading that completes the submission of the matter for resolution.