A.M. No. MTJ-12-1812; June 20, 2012
Pilar S. Tañoco, Complainant, vs. Judge Inocencio B. Sagun, Jr., Presiding Judge, Municipal Trial Court in Cities, Branch 3, Cabanatuan City, Respondent.

FACTS

Complainant Pilar S. Tañoco filed a verified administrative complaint against respondent Judge Inocencio B. Sagun, Jr. for undue delay in rendering judgment in an ejectment case. The case was filed on May 6, 2009, and raffled to the respondent’s sala. The pretrial was concluded on October 13, 2009, and the parties were directed to file their position papers. The plaintiff filed her position paper on November 23, 2009. As of the complaint’s filing on March 4, 2010, the defendant had not filed a position paper, and no decision had been rendered, allegedly violating the Rule on Summary Procedure which mandates a decision within thirty days from the submission of position papers or the lapse of the period to file them.
In his Comment, the respondent judge claimed the pretrial order directing the filing of position papers was issued only on January 26, 2010, and that no prejudice was caused as the defendant had vacated the property. He asserted no intention to delay and noted a Decision was eventually rendered on April 7, 2010. The complainant, in reply, alleged the January 26, 2010 order was mailed only on March 15, 2010, making it appear antedated. The Office of the Court Administrator (OCA) recommended finding the judge guilty and imposing a fine of ₱10,000.

ISSUE

Whether respondent Judge Inocencio B. Sagun, Jr. is administratively liable for undue delay in rendering a decision in the ejectment case.

RULING

Yes, the respondent judge is administratively liable for undue delay. The Supreme Court modified the OCA’s recommendation, imposing a fine of ₱5,000. The Court emphasized that delay in case disposition erodes public faith in the judiciary, and failure to decide within the reglementary period without justifiable reason constitutes gross inefficiency. In this case, the decision was rendered on April 7, 2010, over four months after the plaintiff’s position paper was filed in November 2009, clearly exceeding the 30-day period mandated for ejectment cases under the Rule on Summary Procedure.
Even accepting the judge’s claim that the pretrial order was issued on January 26, 2010, this itself constituted delay. Under the Rules on Summary Procedure and relevant guidelines, a pretrial order must be issued within five to ten days after the pretrial conference, which concluded on October 13, 2009. The issuance over three months later was a separate violation. The Rules on Summary Procedure are designed precisely for expeditious disposition, and judges must handle such cases with promptness. The Court classified undue delay as a less serious charge under the Rules of Court. Considering the respondent’s long tenure since 1997 and that this was only his third administrative charge (with the first dismissed and the second pending), a fine of ₱5,000 was deemed appropriate, with a warning that repetition would merit a more severe sanction.