A.M. No. MTJ-11-1779. July 16, 2012.
MURPHY CHU/ATGAS TRADERS and MARINELLE P. CHU, Complainants, vs. HON. MARIO B. CAPELLAN, Assisting Judge, Metropolitan Trial Court (MeTC), Branch 40, Quezon City, Respondent.

FACTS

Complainants were defendants in an unlawful detainer case before respondent judge. After hearings on a preliminary mandatory injunction, the case was set for preliminary conference. Complainants failed to file a pre-trial brief. During the conference, the plaintiffs orally moved to declare complainants in default for this failure. Complainants, in turn, moved to dismiss the complaint on jurisdictional grounds. Respondent judge issued a Joint Order submitting the case for decision based solely on the allegations in the complaint, effectively declaring complainants in default. Complainants moved for reconsideration, which was denied.
In their administrative complaint, complainants charged respondent with Gross Ignorance of the Law, Partiality, and Grave Abuse of Discretion. They alleged the default declaration was baseless as no formal notice of preliminary conference was issued to them, violating mandatory procedure. They further argued the judge erred in entertaining an oral motion for default, caused delays, and showed bias by not dismissing the case for the plaintiffs’ alleged non-appearance at mediation.

ISSUE

Whether respondent judge is administratively liable for Gross Ignorance of the Law for declaring the complainants in default and submitting the ejectment case for decision based solely on the complaint.

RULING

Yes, respondent judge is guilty of Gross Ignorance of the Law. The Supreme Court found his act of declaring the defendants in default and rendering judgment based only on the complaint to be a gross misapplication of elementary procedural rules, constituting ignorance of the law. The Court clarified that under the Revised Rules on Summary Procedure governing ejectment cases, a defendant’s failure to file a pre-trial brief is not a ground for default. The rules explicitly prohibit a motion to declare a defendant in default. The proper sanction for such failure is to consider the defendant as having waived the right to present evidence, but the court must still require the plaintiff to present evidence ex parte. By instead treating the non-filing as a default and adopting the complaint’s allegations as established facts, respondent judge disregarded this clear procedural rule.
The Court rejected the judge’s defense that no separate notice of preliminary conference was required, finding this irrelevant to the core error. His actions demonstrated a fundamental lack of familiarity with the summary procedure rules he was duty-bound to apply, which is inexcusable. However, the Court found insufficient evidence to substantiate the charges of partiality and undue delay. The charge of Gross Ignorance of the Law was deemed serious, warranting a fine of P20,000.00. The decision underscores that judges must possess basic proficiency in procedural rules, and failure to apply them correctly, especially in summary proceedings designed for expeditious justice, constitutes administratively sanctionable conduct.