A.M. No. MTJ-00-1264; February 4, 2002
Ramir Mina, complainant, vs. Judge Rodolfo Gatdula, respondent.

FACTS

Complainant Ramir Mina, as attorney-in-fact for his parents (defendants in an unlawful detainer case), filed two administrative complaints against respondent Judge Rodolfo Gatdula of the Municipal Trial Court of Balanga, Bataan. The first complaint alleged undue delay in rendering a decision in Civil Case No. 1752, an ejectment case governed by the Rules on Summary Procedure. The case was submitted for decision following the parties’ submission of position papers after the June 19, 1996 hearing. However, Judge Gatdula rendered his decision only on July 7, 1998, exceeding the mandatory 30-day period for decision under the summary rules by approximately two years.
The second complaint accused the judge of rendering an unjust decision, ignorance of the law, and manifest partiality. Mina contended the decision, which ordered his parents to vacate the land, was unsupported by evidence. He specifically argued that the plaintiffs’ key evidence, a Deed of Donation, was spurious, citing discrepancies in the notarial registry and the use of a community tax certificate belonging to another person. Complainant asserted the judge ignored this conclusive defense evidence.

ISSUE

Whether respondent Judge Gatdula is administratively liable for (1) undue delay in rendering a decision, and (2) rendering an unjust decision, ignorance of the law, and manifest partiality.

RULING

The Supreme Court found Judge Gatdula GUILTY of gross inefficiency for undue delay but DISMISSED the charges of rendering an unjust decision, ignorance of the law, and manifest partiality.
On the first charge, the Court ruled the delay was inexcusable. The case fell under the Revised Rules on Summary Procedure, which mandates rendition of judgment within thirty (30) days after receipt of the last affidavits and position papers. The period for deciding the case expired in July 1996, but the decision was promulgated only in July 1998. The judge’s claim that the delay was due to ongoing amicable settlement negotiations was unsubstantiated by the records, which showed such negotiations had concluded by January 1996. This constituted a clear violation of the strict deadlines under summary procedure, warranting administrative sanction for gross inefficiency.
On the second set of charges, the Court held that an administrative complaint is not the proper remedy for correcting judicial errors, which should be addressed through judicial appeals. The records showed complainant’s parents did in fact appeal the decision to the Regional Trial Court, which affirmed it. For a judge to be held administratively liable for a decision, the error must be gross, patent, malicious, deliberate, or in bad faith. The Court found no evidence of bad faith, malice, or corrupt motive. The judge’s assessment of the evidence, including the contested Deed of Donation, pertained to the exercise of judicial discretion. An erroneous judgment, absent proof of ill will, does not constitute ignorance of the law or manifest partiality. The Court imposed a fine of Five Thousand Pesos (₱5,000.00) for gross inefficiency.