Jacinto v. Asis
REITERATIONFacts
The Antecedents: Leticia G. Jacinto (complainant) was the plaintiff in Civil Case No. 05-35013, an unlawful detainer case filed before the Metropolitan Trial Court, Branch 40, Quezon City (MeTC Br. 40). Judge Josephus Joannes H. Asis (respondent) became the Presiding Judge of MeTC Br. 40 in August 2006 and began performing judicial functions in September 2006. Procedural History: On March 9, 2007, Judge Asis issued an Order submitting Civil Case No. 05-35013 for decision. The defendants filed a Motion for Reconsideration, to which Jacinto filed an Opposition on April 19, 2007. Jacinto subsequently filed an Urgent Motion to Submit Incident for Resolution on August 6, 2007. Due to the alleged failure of Judge Asis to promptly render judgment, Jacinto filed the instant administrative complaint on September 14, 2010. The Petition: In his Comment dated October 13, 2010, Judge Asis cited severe medical conditions, including an eye illness, seizures, a mild stroke, an eye operation, hospitalization for brain hemorrhage, and a brain operation requiring ICU confinement, as reasons for his inability to act on the pending motions and render a decision within the reglementary period. The Office of the Court Administrator (OCA) recommended that Judge Asis be found guilty of delay in resolving the Motion for Reconsideration and rendering the Decision, and be fined P2,000.00 with a stern warning. The OCA noted that despite the admitted medical leaves only covering September to November 2007, the Motion for Reconsideration was resolved on October 19, 2010, and the Decision rendered on October 26, 2010, a delay of approximately three years, and that Judge Asis acted on these matters only after being directed to comment on the complaint.
Issue(s)
Whether Judge Josephus Joannes H. Asis is guilty of undue delay in the disposition of Civil Case No. 05-35013. Whether the mitigating circumstances presented by Judge Asis absolve him from administrative liability.
Ruling
The Supreme Court found Judge Josephus Joannes H. Asis guilty of undue delay in the disposition of Civil Case No. 05-35013. He was ordered to pay a fine of P1,000.00, with a warning that the commission of the same or a similar offense will be dealt with more severely.
Ratio Decidendi
On Whether Judge Josephus Joannes H. Asis is guilty of undue delay in the disposition of Civil Case No. 05-35013: The Court held that Judge Asis is guilty of undue delay. Civil Case No. 05-35013 was an action for unlawful detainer covered by the Revised Rule on Summary Procedure, which requires judges to render judgment within 30 days after submission. While Judge Asis's severe ailments and medical operations understandably prevented him from deciding the case within the prescribed period, the Court agreed with the OCA that the prudent course of action would have been for him to request an an extension for acting on the case instead of disposing of it only after being prompted to file a comment on the present complaint. The delay of approximately three years in resolving the Motion for Reconsideration and rendering the Decision, despite his admitted leave of absence being only for September to November 2007, clearly constitutes undue delay. Judges are continuously reminded to resolve cases with dispatch to avoid any delay in the administration of justice, and undue delay in rendering a decision or order is considered a less serious charge under Section 9(1), Rule 140 of the Rules of Court. On Whether the mitigating circumstances presented by Judge Asis absolve him from administrative liability: The Court ruled that while the mitigating circumstances presented by Judge Asis, namely his serious medical conditions and operations, were considered, they did not entirely absolve him from administrative liability. The OCA correctly pointed out that although he had valid reasons for not being able to decide the case within the 30-day reglementary period, these reasons do not totally absolve him from administrative liability. The Court, however, deemed the reduction of the fine proper, considering the existence of factors that mitigated the commission of the offense, specifically that this was his first infraction and that his delay resulted from his serious medical conditions. Nevertheless, the Court emphasized that the prudent course of action would have been for Judge Asis to request an extension of time to decide the case soon after he reported back to work, which would have allowed him to apprise litigants of the status and reason for the delay. The imposition of a fine of P1,000.00, a modification of the OCA's recommendation of P2,000.00, reflects the Court's consideration of these mitigating factors while still holding him accountable for the delay.
Main Doctrine
Judges are expected to resolve cases with dispatch. Undue delay in rendering a decision or order constitutes a less serious charge under Rule 140 of the Rules of Court. While serious medical conditions and operations can be considered mitigating circumstances that may warrant a reduction in the imposed fine, they do not entirely absolve a judge from administrative liability, especially if the judge fails to request an extension of time to decide the case and only acts after being prompted by a complaint.