A.M. No. MTJ-00-1269; August 24, 2000
Dominga D. Quilal-lan, complainant, vs. Judge Alicia L. delos Santos, Municipal Trial Court, Digos, Davao del Sur, respondent.

FACTS

Complainant Dominga D. Quilal-lan filed an administrative complaint against Judge Alicia L. delos Santos for the judge’s failure to render judgment within the prescribed period in Civil Case No. 2554-98, a forcible entry case governed by the Revised Rule on Summary Procedure. The complainant’s daughter was a defendant in that case. Respondent judge, in an order dated August 7, 1998, gave the parties 30 days to submit their position papers. The defendants filed their position paper on September 8, 1998, while the plaintiff failed to submit any. The defendants subsequently filed a motion for rendition of judgment on September 21, 1998, but as of the complaint’s filing on October 21, 1998, no decision had been rendered.
In her comment, respondent judge explained she was on sick leave from November 15, 1998, and was hospitalized until January 15, 1999, which prevented her from deciding the case. She claimed her decision was only due on December 7, 1998. She submitted her approved sick leave application and a medical certificate as supporting evidence and prayed for the complaint’s dismissal.

ISSUE

Whether respondent Judge Alicia L. delos Santos is administratively liable for failing to decide a forcible entry case within the period mandated by the Revised Rule on Summary Procedure.

RULING

Yes, respondent judge is administratively liable. The Court ruled that the case, being one for forcible entry, was covered by the Revised Rule on Summary Procedure. Under Section 10 of said rule, judgment must be rendered within thirty (30) days after receipt of the last affidavits and position papers or the expiration of the period for filing them. The period for filing position papers expired on September 6, 1998. Consequently, the judgment was due on October 6, 1998. The respondent judge’s claim that the decision was only due on December 7, 1998, was incorrect.
The legal logic is clear: the mandatory period for deciding summary procedure cases is absolute and is calculated from the expiration of the filing period, not from any later date of actual submission. The respondent’s subsequent sick leave beginning November 16, 1998, was irrelevant, as it commenced over a month after the October 6, 1998, deadline. Her failure to decide before going on leave constituted a violation of Rule 3.05 of the Code of Judicial Conduct, which requires judges to dispose of court business promptly. This delay defeats the very purpose of the summary procedure rule—speedy disposition of cases. The Court imposed a fine of P1,000.00, with a warning that a repetition would be dealt with more severely.