G.R. No. MTJ-05-1583. March 11, 2005.
Manuel B. Arcenas, Complainant, vs. Judge Henry B. Avelino, MCTC, Pontevedra, Capiz, Respondent.

FACTS

Complainant Manuel B. Arcenas, as attorney-in-fact for the plaintiffs in an unlawful detainer case, charged respondent Judge Henry B. Avelino with gross inefficiency for failing to decide the case within the mandatory 30-day period under the Revised Rules on Summary Procedure. The defendants failed to file an answer. Instead of rendering judgment, the judge issued orders directing government agencies to conduct relocation surveys concerning a 20-meter public easement reservation noted on the plaintiff’s title. He later conducted his own ocular inspection.
Despite the plaintiffs filing an ex parte motion for judgment in November 2003 and a follow-up motion in March 2004, the judge took no action. The administrative complaint was filed in April 2004. The judge admitted he rendered judgment only in May 2004, nearly three years after the defendants’ failure to answer. He justified the delay by claiming a need to determine if the defendants’ house was within the public easement, which he believed was beyond his authority to adjudicate in an ejectment suit.

ISSUE

Whether respondent Judge Henry B. Avelino is administratively liable for gross inefficiency due to his undue delay in deciding an ejectment case governed by the Revised Rules on Summary Procedure.

RULING

Yes, the respondent judge is administratively liable. The Supreme Court found him guilty of gross inefficiency for undue delay in rendering judgment. The legal logic is anchored on the mandatory and indispensable nature of procedural time limits designed to prevent needless delays and ensure the speedy discharge of judicial business. For cases under the Revised Rules on Summary Procedure, Section 10 explicitly requires rendition of judgment within thirty days from receipt of the last affidavit or expiration of the filing period. Furthermore, Section 6 provides that if a defendant fails to answer, the court shall render judgment based on the facts alleged in the complaint.
The Court ruled that the judge’s justification for the delay was untenable. His duty was to resolve the ejectment case based on the pleadings before him. The issue of a public easement reservation, even if raised, did not excuse his failure to comply with the strict, non-extendible period mandated for summary procedure. His actions—ordering surveys and conducting inspections—constituted an unwarranted deviation from the summary nature of the proceedings and caused unjustified delay. The Court emphasized that judges must dispose of court business promptly as required by the Code of Judicial Conduct. Considering his admission of fault and the aggravating circumstance of the damage caused by the delay, the Court modified the OCA’s recommendation and imposed a fine of Twenty Thousand Pesos (P20,000.00) with a stern warning.