G.R. No.: A.M. No. MTJ-11-1792; September 26, 2011 (Formerly OCA I.P.I No. 10-2294-MTJ)
Case Title: Ernesto Z. Orbe, Complainant, vs. Judge Manolito Y. Gumarang, Pairing Judge, Municipal Trial Court, Imus, Cavite, Respondent.

FACTS

Complainant Ernesto Z. Orbe was the plaintiff in a small claims case (Civil Case No. ICSCC 09-65) before the MTC of Imus, Cavite. After the parties failed to reach an amicable settlement on February 9, 2010, the case was reassigned to respondent Judge Manolito Y. Gumarang, the Assisting Judge, for trial. The hearing scheduled for March 4, 2010, was postponed by respondent due to a power interruption. The reset hearing on March 11, 2010, was again postponed by respondent because he was due for a medical check-up. On March 25, 2010, respondent conducted another Judicial Dispute Resolution (JDR), and after the parties failed to settle, he reset the hearing to April 15, 2010. Complainant alleged that respondent violated the Rule of Procedure for Small Claims Cases by failing to decide the case within five (5) days from receipt of the order of reassignment, as mandated by Section 22 of the Rule. In his Comment, respondent admitted the failure to decide within the prescribed period but argued that the five-day period should be construed as five calendared trial dates falling only on Thursdays, as he allotted only that day to hear small claims cases.

ISSUE

Whether respondent Judge Manolito Y. Gumarang is administratively liable for Undue Delay in Rendering a Decision and for Violation of the Rule of Procedure for Small Claims Cases.

RULING

Yes, respondent is administratively liable. The Supreme Court agreed with the Office of the Court Administrator’s (OCA) findings and recommendation. Section 22 of the Rule of Procedure for Small Claims Cases explicitly requires the newly assigned judge to hear and decide the case within five (5) days from receipt of the order of reassignment. Respondent’s interpretation—that the five-day period referred only to his designated hearing day (Thursdays)—was erroneous and contrary to the Rule’s clear and unambiguous language. The Court emphasized that the Rule was created to provide a simple, informal, and expeditious process to enhance access to justice for small claims, and its intent for prompt resolution is a matter of public policy. The multiple postponements, some initiated by respondent after settlement efforts had already failed, constituted a clear violation and defeated the Rule’s very purpose. The Court held that failure to apply such basic procedural rules constitutes gross ignorance of the law. While undue delay in rendering a decision is a less serious charge under the Revised Rules of Court, punishable by suspension or a fine of more than ₱10,000 but not exceeding ₱20,000, the Court considered that the Small Claims Rule was relatively new and this was respondent’s first violation. Therefore, the Court found respondent GUILTY of Undue Delay in Rendering a Decision and Violation of the Rule of Procedure for Small Claims Cases and ordered him to pay a fine of Five Thousand Pesos (₱5,000.00) with a warning that a repetition would be dealt with more severely.