A.M. No. MTJ-00-1249. September 4, 2001.
Philippine Geriatrics Foundation, Inc., Atty. Eduardo S. Rodriguez, and Atty. Vicente S. Pulido, complainants, vs. Judge Lydia Querubin Layosa, respondent.

FACTS

This administrative complaint arose from an unlawful detainer case (Civil Case No. 150316-CV) filed by the Philippine Geriatrics Foundation, Inc. (PGF) against Ligaya Santos before the Metropolitan Trial Court (MeTC) of Manila, Branch 12, presided by respondent Judge Lydia Querubin Layosa. PGF sought to eject Santos from a canteen it claimed to own and lease to her. Judge Layosa dismissed the complaint on February 6, 1997, ruling that PGF failed to prove the existence of a lease contract. PGF appealed this decision to the Regional Trial Court (RTC), which affirmed the dismissal, but the Court of Appeals (CA) later reversed the RTC and ordered Santos to vacate.
The complainants, PGF and its lawyers, filed this administrative case against Judge Layosa on May 21, 1997, alleging gross ignorance of the law, gross misconduct, and grave abuse of discretion. They specifically accused her of: (1) erroneously ruling that no lease existed and ignoring the principle of possession by tolerance; (2) failing to render judgment within the 30-day period mandated by the Revised Rules on Summary Procedure, as the decision was promulgated 74 days after the last position paper was filed; and (3) improperly rejecting secondary evidence on the lease.

ISSUE

Whether respondent Judge Lydia Querubin Layosa should be held administratively liable for gross ignorance of the law, gross misconduct, and grave abuse of discretion based on her handling and decision in the unlawful detainer case.

RULING

The Supreme Court dismissed the charges of gross ignorance of the law and grave abuse of discretion but found respondent liable for undue delay in rendering judgment. The Court emphasized that a judge cannot be held administratively accountable for every erroneous judgment, as judicial fallibility is recognized. The proper remedy for an aggrieved party is judicial appeal, not an administrative complaint. The fact that the RTC initially affirmed Judge Layosa’s decision, even though the CA later reversed it, negated any finding of gross, deliberate, or malicious error indicative of bad faith.
However, the Court found Judge Layosa administratively liable for gross misconduct for failing to decide the case within the 30-day period prescribed by the Revised Rules on Summary Procedure. She admitted the delay, attributing it to inadvertence due to work pressure and the Christmas rush. The Court found this explanation insufficient, noting she had managed to request an extension for another case during the same period but failed to do so for this case. This failure constituted a violation of Canon 3, Rule 3.05 of the Code of Judicial Conduct, which mandates the prompt disposition of court business. Delay in case disposition infringes on the constitutional right to a speedy disposition of cases. Consequently, Judge Layosa was REPRIMANDED for the undue delay and warned that a repetition would be dealt with more severely.