A.M. No. 127-MJ. August 31, 1977. CUSTODIO ESCABILLAS, complainant, vs. HON. LUIS D. MARTINEZ, Municipal Judge of Hagonoy, Davao del Sur, respondent.
FACTS

Complainant Custodio Escabillas charged respondent Municipal Judge Luis D. Martinez with gross misconduct, gross ignorance of the law, and unreasonable delay in deciding a case. The core dispute involved a parcel of land (Lot A) purchased by Escabillas, which was subject to a lease in favor of the Bangayans. In a prior civil case, the Court of First Instance (CFI) of Davao del Sur had ruled that this lease contract expired on April 15, 1970, an order which was subsequently affirmed by the Supreme Court. Following this finality, Escabillas filed an unlawful detainer case (Civil Case No. 261) against the Bangayans before Judge Martinez’s court to recover possession of the lot.
The unlawful detainer case was submitted for decision on March 3, 1972. Judge Martinez rendered his decision on August 31, 1972, ordering the Bangayans to surrender the lot to Escabillas after receiving a payment of P9,000.00 from him, and to pay attorney’s fees. Escabillas alleged that by ordering this payment, the judge effectively extended the terms of the already expired lease contract, defying the final order of the higher court. He further accused the judge of palpable incompetence for failing to decide the case within the 90-day reglementary period.

ISSUE

The issues were: (1) Whether respondent judge committed gross misconduct and gross ignorance of the law by allegedly extending an expired lease contract; and (2) Whether he incurred unreasonable delay and palpable incompetence for failing to decide the case within 90 days from its submission.

RULING

The Supreme Court dismissed the charge of gross misconduct and ignorance of the law but found the respondent judge liable for unreasonable delay. On the first charge, the Court found no merit. A review of Judge Martinez’s decision in Civil Case No. 261 revealed that he explicitly recognized the CFI order declaring the lease expired on April 15, 1970, as final and binding. He expressly stated he had no authority to alter, amend, or reverse that final order, which had been affirmed by the Supreme Court. The award of P9,000.00 to the Bangayans was not a modification of the lease terms but a separate determination based on the evidence presented during the unlawful detainer trial regarding the defendants’ counterclaims or equities. Therefore, the judge did not defy a higher court’s verdict.
However, the Court sustained the charge of unreasonable delay. The case was submitted for decision on March 3, 1972, and decided on August 31, 1972, a delay exceeding five months, which clearly violated the mandatory 90-day period prescribed by Section 5 of the Judiciary Act of 1948 ( Republic Act No. 296 ). The judge’s explanation attributing the delay to the voluminous records and the need for prudent evaluation was rejected as insufficient. The Court emphasized that strict compliance with the 90-day rule is essential to the speedy administration of justice. Delay congests dockets, causes loss of evidence, and brings the judiciary into disrepute. Consequently, while the serious charges were dismissed, Judge Martinez was reprimanded for the undue delay and sternly enjoined to observe the mandatory period for deciding cases.