A.M. No. 866-CJ July 31, 1975
Miguel Agilada, complainant, vs. Judge Aloysius C. Alday, City Court, Branch II, Quezon City, respondent.

FACTS

Complainant Miguel Agilada, a defendant in an ejectment case, filed an administrative complaint against respondent Judge Aloysius C. Alday. Agilada alleged that the judge exhibited partiality and ignorance of the law by refusing to dismiss the ejectment suit despite the complaint stating that Agilada had not paid rentals from April 1970 to June 1974. Agilada argued this period exceeded the one-year reglementary period for filing an unlawful detainer case under the Rules of Court. He further accused the judge of abuse of authority for setting an excessive number of cases daily, causing hardship and inconvenience to litigants.
In his comment, Judge Alday clarified that the cause of action for ejectment accrued not from the initial failure to pay in 1970, but from the plaintiff’s formal demand to vacate made on May 21, 1974, and reiterated in June 1974. He explained that under Rule 70, the one-year period is counted from the date of the last demand to vacate and the tenant’s subsequent refusal, not from the first instance of non-payment. Regarding the calendar, he asserted the number of cases set was reasonable and consistent with the court’s workload.

ISSUE

Whether respondent Judge Alday is administratively liable for partiality, ignorance of the law, and abuse of authority based on the allegations.

RULING

The Supreme Court dismissed the complaint for lack of merit. The Court found no basis for the charges of partiality or ignorance of the law. The legal logic is clear: the one-year prescriptive period for filing an ejectment case based on failure to pay rent is reckoned from the date of the lessor’s demand to vacate and the lessee’s refusal, not from the start of the rental arrears. Respondent Judge correctly applied Sections 1 and 2 of Rule 70 and pertinent jurisprudence. Thus, his denial of the motion to dismiss was legally sound, not an act of partiality or ignorance. The complainant’s misunderstanding of this technical legal doctrine does not translate to judicial misconduct.
Regarding the alleged abuse of authority in calendar management, the Court held that such administrative discretion is vested in the judge and is entitled to respect, absent any showing of arbitrariness. No other litigant had complained about this practice. The Court noted that complaints from laypersons, while a constitutional right, should be filed with care, especially on technical legal grounds, to avoid frivolous charges stemming from a litigant’s own frustration or lack of legal knowledge. The respondent judge satisfactorily explained his actions, demonstrating the accusations were unfounded.