A.M. No. MTJ-03-1513. November 12, 2003. Spouses Jaime and Purificacion Morta, Complainants, vs. Judge Antonio C. Bagagñan, Municipal Trial Court, Guinobatan, Albay; and Sheriff Danilo O. Matias, Regional Trial Court, Branch 14, Ligao, Albay, Respondents.
FACTS

Spouses Jaime and Purificacion Morta filed an administrative complaint against Judge Antonio C. Bagagñan for gross ignorance of the law, incompetence, bias, and delay, and against Sheriff Danilo O. Matias for gross ignorance, negligence, and connivance. The complainants were plaintiffs in two civil cases for damages where the MTC ruled in their favor in 1994. After appeals, the Supreme Court reinstated the MTC decision on June 10, 1999. The complainants alleged that despite the finality of the Supreme Court’s decision, Judge Bagagñan refused to issue a writ of possession in their favor. They further charged that a motion for contempt they filed on June 6, 2000, remained unresolved for over a year. Against Sheriff Matias, they averred that he failed to fully implement a writ of execution and delayed submitting his sheriff’s return.
In his defense, Judge Bagagñan explained he denied the motion for a writ of possession because the complainants had already been legally ousted from the property via a separate final DARAB decision and a civil case. Regarding the unresolved contempt motion, he claimed an ocular inspection and hearing were conducted, but proceedings were deferred pending a sheriff’s report. Sheriff Matias admitted the delay in implementing the writ, attributing it to a heavy workload and pleading for compassion.

ISSUE

Whether respondents Judge Bagagñan and Sheriff Matias are administratively liable for the alleged delays in resolving a motion and implementing a writ of execution.

RULING

Yes, both respondents are administratively liable. The Court found Judge Bagagñan guilty of undue delay in resolving the motion for contempt. Judges are mandated to dispose of court business promptly and decide matters within required periods. His justification for the delay—awaiting a sheriff’s report—was insufficient, as he should have taken proactive steps to obtain the report or resolved the motion based on available records. His failure to act on the motion for over a year constituted a violation of the Code of Judicial Conduct and warranted a fine of P11,000.
Sheriff Matias was likewise held liable for the unjustified delay in implementing the writ of execution and in submitting his return. Sheriffs must perform their duties with reasonable celerity and are required to submit a return promptly after executing a writ. His plea of heavy workload does not exonerate him, as it is not a valid excuse for neglecting a specific duty. To avoid leaving his post unattended, the Court imposed a fine equivalent to one month’s salary instead of suspension. The ruling reinforces the principle that justice delayed is justice denied, holding court personnel accountable for unreasonable delays that undermine the efficient administration of justice.