Tañoco v. Sagun
REITERATIONFacts
The Antecedents: Complainant Pilar S. Tañoco filed a verified Complaint against respondent Judge Inocencio B. Sagun, Jr. for undue delay in rendering judgment. An ejectment case was filed on May 6, 2009, before the Municipal Trial Court in Cities (MTCC), Branch 3, Cabanatuan City, and was raffled to respondent's sala. Pre-trial was concluded on October 13, 2009, and parties were directed to file their position papers. The plaintiff filed her position paper on November 23, 2009. As of the filing of the Complaint, the defendant had not filed their position paper, nor had the respondent judge rendered a decision, allegedly violating the Rule on Summary Procedure which requires ejectment cases to be decided within thirty (30) days from the submission of position papers. Procedural History: Respondent judge, in his Comment, stated that the pre-trial Order directing the filing of position papers was issued only on January 26, 2010. He also claimed no prejudice to the plaintiff as the defendant had vacated the property, and there was no intention to delay. He further stated that a Decision was rendered on April 7, 2010. Complainant, in reply, averred that the January 26, 2010 pre-trial Order was mailed only on March 15, 2010, suggesting it was antedated. The Office of the Court Administrator (OCA) recommended that the respondent be found guilty of Undue Delay in Rendering Judgment/Decision and be fined P10,000 with a warning. The Petition: The case before the Supreme Court is an administrative complaint filed by Pilar S. Tañoco against Judge Inocencio B. Sagun, Jr. for undue delay in rendering judgment in an ejectment case. The complainant alleged violations of the Rule on Summary Procedure due to the judge's failure to decide the case within the reglementary period after the submission of position papers. The respondent judge raised defenses including the timing of the pre-trial order and the absence of prejudice. The OCA recommended a penalty, which the Supreme Court reviewed.
Issue(s)
Whether respondent Judge Inocencio B. Sagun, Jr. is guilty of undue delay in rendering judgment in the ejectment case. Whether the penalty recommended by the Office of the Court Administrator is appropriate.
Ruling
The Supreme Court found Judge Inocencio B. Sagun, Jr. liable for delay in the disposition of the ejectment case. Accordingly, he was fined P5,000.00 and warned that a repetition of the same or similar act would merit a more severe sanction.
Ratio Decidendi
On Whether respondent Judge Inocencio B. Sagun, Jr. is guilty of undue delay in rendering judgment in the ejectment case: The Court found the respondent judge guilty of undue delay. The decision was purportedly issued on April 7, 2010, which was more than four months after the last submission of the parties' position paper. Even considering the respondent's argument that the pre-trial Order was issued on January 26, 2010, this was still more than three months after the pre-trial itself. Section 8 of the Rules on Summary Procedure mandates that within five days after the termination of the preliminary conference, the court shall issue an order stating the matters taken up therein. Furthermore, paragraph 8, Title I(A) of A.M. No. 03-1-09-SC requires a judge to issue a pre-trial order within 10 days after the termination of the pre-trial. Since the ejectment case fell under the Rules on Summary Procedure, the respondent judge should have handled it with promptness and haste, as the purpose of these rules is precisely to prevent undue delays. The Court found that the delay was not justified. On Whether the penalty recommended by the Office of the Court Administrator is appropriate: The Court found the OCA recommendation appropriate with a modification. Section 9, Rule 140 of the Rules of Court classifies undue delay in rendering a decision or order as a less serious charge, punishable by suspension or a fine of more than P10,000 but not exceeding P20,000. Considering that this was only the third administrative charge against the respondent judge (the first dismissed, the second pending) and his relatively long tenure since 1997, the Court deemed a fine of P5,000.00 to be a reasonable penalty for being administratively liable for undue delay in rendering a decision. The respondent was also warned that a repetition of the same or a similar offense would result in a more severe sanction.
Main Doctrine
Undue delay in rendering a decision or order, particularly in cases covered by the Rules on Summary Procedure, constitutes gross inefficiency and is a less serious charge under the Rules of Court, punishable by suspension or a fine. Judges are mandated to decide ejectment cases within thirty (30) days from the submission of position papers and to issue pre-trial orders within ten (10) days after the termination of pre-trial, as stipulated by relevant rules and administrative issuances.