Chu v. Capellan
REITERATIONFacts
The Antecedents: Complainants spouses Murphy and Marinelle P. Chu and ATGAS Traders (complainants) charged Judge Mario B. Capellan (respondent), Assisting Judge of the Metropolitan Trial Court (MeTC), Branch 40, Quezon City, with Gross Ignorance of the Law, Partiality and Grave Abuse of Decision. The charge stemmed from an unlawful detainer complaint filed by spouses Ofelia and Rafael Angangco against the complainants. The complainants filed their answer with compulsory counterclaim. The respondent heard the application for a writ of preliminary mandatory injunction (PMI) on several dates. The unlawful detainer case was set for preliminary conference multiple times, with delays and reschedulings. The respondent denied the application for a writ of PMI and set the case for preliminary conference. The case was referred for mediation, and the preliminary conference was reset again. The spouses Angangco filed their pre-trial brief, but the complainants did not. During a preliminary conference, the complainants moved for consignation of checks, and clarificatory hearings were set. The preliminary conference finally took place. The complainants moved to dismiss the unlawful detainer complaint on grounds of failure to comply with barangay conciliation and to implead co-owners, and lack of jurisdiction to issue a writ of PMI. The spouses Angangco orally moved to declare the complainants in default for failure to file a pre-trial brief. Procedural History: On February 26, 2009, the respondent issued a joint order submitting the unlawful detainer case for decision based on the facts alleged in the unlawful detainer complaint. The complainants moved for reconsideration, which was denied. The complainants filed the present administrative complaint and a motion for inhibition. The respondent eventually inhibited himself from the case. The complainants alleged that the respondent had no basis to declare them in default due to lack of notice of preliminary conference, and that the respondent erred in entertaining the oral motion to declare them in default, incurred delay, and did not dismiss the complaint for failure of the spouses Angangco to appear personally during mediation. The respondent argued that no notice of preliminary conference was required, and that A.M. No. 01-2-04 was inapplicable. The Office of the Court Administrator (OCA) found no merit in most allegations but found merit in the allegation of undue delay in setting the case for preliminary conference. The OCA recommended a reprimand with a stern warning. The administrative complaint was redocketed as a regular administrative case. The Petition: The complainants filed the present administrative complaint against the respondent judge, alleging gross ignorance of the law, partiality, and grave abuse of decision. They contended that the respondent erred in submitting the case for decision without issuing a notice of preliminary conference and in entertaining an oral motion to declare them in default. They also alleged undue delay in the proceedings.
Issue(s)
Whether the respondent judge committed gross ignorance of the law, partiality, and grave abuse of discretion in not issuing a notice for the holding of the preliminary conference and in entertaining the spouses Angangco’s oral motion to declare the defendants in default. Whether Supreme Court A.M. No. 01-2-04 may be suppletorily applied to the subject unlawful detainer case. Whether the failure of the spouses Angangco to personally appear during the mediation proceedings was a ground to dismiss the unlawful detainer complaint. Whether the respondent judge incurred undue delay in setting the case for preliminary conference.
Ruling
The Court found no merit in the allegations of gross ignorance of the law, partiality, and grave abuse of discretion. However, it found the respondent judge guilty of undue delay in rendering a decision or order. The respondent judge was ordered to pay a FINE of Twenty Thousand Pesos (P20,000.00).
Ratio Decidendi
On the alleged gross ignorance of the law, partiality, and grave abuse of discretion regarding the notice of preliminary conference and motion to declare in default: The Court ruled that the respondent judge did not commit gross ignorance of the law, partiality, or grave abuse of discretion. The order dated October 7, 2008, which set the case for preliminary conference on November 25, 2008, constituted sufficient notice to the parties. Both parties received copies of this order, thus negating the claim of denial of due process. Furthermore, the Court clarified that the respondent judge did not entertain the oral motion to declare the defendants in default. Instead, the joint order dated February 26, 2009, which submitted the case for decision, was a consequence of the complainants' failure to file their pre-trial brief as mandated by Section 7 of Rule 70 in relation to Section 8 of Rule 70 and Section 6 of Rule 18 of the Rules of Court. The respondent judge treated the oral motion as a motion to render judgment, which was a proper course of action given the complainants' failure to file their pre-trial brief. On the applicability of Supreme Court A.M. No. 01-2-04: The Court held that Supreme Court A.M. No. 01-2-04, which pertains to the Proposed Interim Rules of Procedure Governing Intra-Corporate Controversies under R.A. No. 8799, cannot be suppletorily applied to the subject unlawful detainer case. The administrative memorandum specifically governs intra-corporate controversies and does not include ejectment cases. There is no provision within A.M. No. 01-2-04 that permits its suppletory application to ejectment cases. Therefore, the complainants' reliance on this administrative circular was misplaced. On the failure of the spouses Angangco to personally appear during mediation: The Court found that the personal non-appearance of a party at mediation may be excused when the party is duly represented by counsel authorized to enter into amicable settlement or submit to alternative modes of dispute resolution. In this case, the spouses Angangco were represented by their lawyer during the mediation proceedings. Citing Senarlo v. Paderanga, the Court affirmed that such representation is permissible and does not constitute a ground for dismissing the unlawful detainer complaint. On the undue delay in setting the case for preliminary conference: The Court found merit in the complainants' allegation that the respondent judge incurred undue delay. The Revised Rules on Summary Procedure requires a preliminary conference to be held not later than thirty (30) days after the last answer is filed. The unlawful detainer case was filed on March 22, 2007, and the answer was filed on March 30, 2007. However, the respondent judge set the preliminary conference only on June 24, 2008, which was significantly beyond the 30-day period. Furthermore, the frequent resetting of the preliminary conference dates, with the final conference being held almost two years after the answer was filed, demonstrated a failure to exert authority in expediting the proceedings. This undue delay violates Section 7 of the 1991 Revised Rules on Summary Procedure and Rule 1.02, Canon 1 of the Code of Judicial Conduct, which mandates judges to administer justice without delay. The Court reiterated that undue delay erodes public faith in the judicial system and can invite suspicion of ulterior motives.
Main Doctrine
Judges are mandated to administer justice without delay. Failure to comply with the prescribed periods for preliminary conferences under the Revised Rules on Summary Procedure constitutes undue delay, which is a less serious charge under the Rules of Court. Errors committed in the exercise of adjudicative functions cannot be corrected through administrative proceedings where judicial remedies are available, unless the assailed order is manifestly erroneous or impelled by ill-will, malice, or other similar motive.