Alconera v. Majaducon
REITERATIONFacts
The Antecedents: Complainant Atty. Virgilio P. Alconera filed a complaint for forcible entry against Faustino Labao on behalf of Dioscoro Bactol and Elizabeth Bactol Viquiera. The case was assigned to respondent Judge Jose S. Majaducon. Summons was served on April 4, 1997. Defendant Labao filed an unverified answer on April 19, 1997, beyond the ten-day period prescribed by the 1991 Revised Rule on Summary Procedure. Respondent admitted the late and unverified answer and set the case for preliminary conference. Plaintiffs filed a motion for summary judgment or judgment on the pleadings due to the late and unverified answer, which respondent did not act upon. Three preliminary conferences were held. On May 26, 1997, despite defendant Labao's absence, the conference proceeded, and parties were given 15 days to submit position papers. Respondent also gave Labao 10 days to move for reconsideration regarding his absence. On June 9, 1997, plaintiffs filed their position paper. Labao, through counsel, filed a motion to file answer through counsel, which respondent granted, directing Labao to file his position paper. Labao never filed either. Procedural History: On October 9, 1997, respondent declared the case submitted for decision. On November 3, 1997, he rendered a decision in favor of Labao, dismissing the complaint. Complainant then filed the instant administrative case against respondent for gross ignorance of the law or procedure and/or grave misconduct for manifest bias. The Office of the Court Administrator (OCA) recommended a fine of P10,000 for gross ignorance of the law. The case was referred for investigation, but due to various circumstances including respondent's promotion to RTC judge, it was reassigned multiple times. Complainant later informed the Court he was withdrawing his complaint, but was advised that administrative cases are not dependent on the complainant's interest. Respondent retired on February 24, 2002. The Third Division of the Supreme Court set aside P100,000 of his retirement benefits due to pending administrative cases. Investigator Justice Juan Enriquez found respondent guilty of gross ignorance of the law and recommended a fine of P20,000. The Petition: The main issue was whether respondent was guilty of gross ignorance of the law or procedure, and whether the complainant's withdrawal of charges was a valid ground for dismissal.
Issue(s)
Whether the withdrawal of the complaint by the complainant renders the administrative case moot. Whether respondent Judge Majaducon committed gross ignorance of the law or procedure by violating the Revised Rule on Summary Procedure. Whether respondent Judge Majaducon exhibited bias towards the defendant, and the appropriate penalty.
Ruling
The Court found Judge Jose S. Majaducon guilty of gross ignorance of procedure and imposed a fine of P40,000. The Court also directed that a copy of the decision be furnished to the Committee on Bar Discipline of the Integrated Bar of the Philippines for the investigation of complainant Atty. Virgilio P. Alconera for trifling with the time and resources of the Court.
Ratio Decidendi
On the issue of withdrawal of the complaint: The Court reiterated the ruling in Gamboa v. Gamboa and Rizon v. Zerna, stating that an administrative case, once filed, ceases to be dependent on the interest of the complainant. The Court emphasized that public interest is at stake in the conduct of judicial officers, and the Court cannot be bound by the unilateral act of a complainant in matters relating to its disciplinary power. Therefore, the complainant's manifestation of withdrawal was of no moment. On the issue of gross ignorance of the law or procedure: The Court found respondent Judge Majaducon guilty of gross ignorance of the law or procedure. The Revised Rule on Summary Procedure, specifically Sections 5 and 6, mandates that a defendant must file an answer within ten days from service of summons, and should the defendant fail to do so, the court shall, motu proprio or on motion of the plaintiff, render judgment as warranted by the facts alleged in the complaint. The word "shall" indicates that rendering judgment is mandatory and not discretionary. Respondent violated this rule by admitting the defendant's late and unverified answer and by granting a motion for extension to file an answer, which is prohibited under Section 19(e) of the Rule on Summary Procedure. These actions defeated the summary nature of the case. On the issue of bias and the penalty: The Court found that respondent Judge Majaducon bent over backwards several times by admitting late and unauthorized pleadings and by granting undue extensions to the defendant. Whether these actions were motivated by bias was irrelevant because they violated the letter and spirit of the Rule on Summary Procedure. The stringent time limits and exclusion of certain pleadings in summary proceedings are intended for efficient and expeditious disposal of cases, which was the opposite of what occurred in respondent's sala. The Court also found no sufficient basis for the alleged closeness between the respondent and the defendant. Considering that this was not respondent's first offense, as indicated by previous administrative cases resulting in fines, the Court imposed the maximum fine of P40,000, disagreeing with the investigator's recommendation of P20,000. This amount was to be deducted from the P100,000 set aside from respondent's retirement benefits.
Main Doctrine
A judge who violates the mandatory provisions of the Revised Rule on Summary Procedure by accepting a late answer and granting extensions for pleadings, even if not motivated by bias, commits gross ignorance of the law or procedure. The withdrawal of a complaint in an administrative case does not divest the Court of its jurisdiction to investigate and decide the case, as public interest is at stake.