AM 00 1258 MTJ; (March, 2000) (Digest)
G.R. No. A.M. No. 00-1258-MTJ March 22, 2000
Spouses Conrado and Maita Seña, complainants, vs. Judge Ester Tuazon Villarin, Metropolitan Trial Court of Las Piñas, Branch 79, respondent.
FACTS
Complainants Spouses Seña, plaintiffs in a forcible entry case (Civil Case No. 4304), charged respondent Judge Ester Tuazon Villarin with unreasonable delay. The defendants filed a Notice of Appeal on March 11, 1998. Subsequently, the complainants filed a Motion for Immediate Execution on April 2, 1998, arguing the appeal was not perfected due to the defendants’ failure to post a supersedeas bond. As of their complaint in July 1998, the Metropolitan Trial Court (MeTC) had not acted upon either the notice of appeal or the motion for execution for over three months, despite follow-ups.
In her Comment, Judge Villarin did not refute the material allegations of delay. She merely informed the Court that the case records were forwarded to the Regional Trial Court (RTC) on July 21, 1998, where the appeal was raffled and pending. She offered no explanation for her inaction on the pending incidents before her court.
ISSUE
Whether respondent Judge Villarin is administratively liable for gross inefficiency due to her failure to act promptly on the Notice of Appeal and Motion for Immediate Execution.
RULING
Yes, respondent Judge is guilty of gross inefficiency. Her silence on the material allegations in the complaint, given the opportunity to comment, is deemed an admission. The facts conclusively demonstrate undue delay. The Notice of Appeal was filed on March 11, 1998, but the order for transmittal was issued only on June 17, 1998—a delay of 98 days. The actual transmittal to the RTC occurred on July 21, 1998, another 34 days later. Furthermore, the Motion for Immediate Execution filed on April 2, 1998, remained unacted upon.
This inaction violates the constitutional mandate for lower courts to decide matters within three months. The delay is particularly egregious as forcible entry cases fall under the Rule on Summary Procedure, which is designed precisely for expeditious resolution. By failing to act promptly, the judge undermined this public policy and the judiciary’s duty to administer justice without delay. Judges must decide cases and incidents within reglementary periods; failure constitutes gross inefficiency. Accordingly, the Court fined Judge Villarin Five Thousand Pesos (P5,000.00) and issued an admonition.