A.M. No. MTJ-12-1818. February 13, 2013. ATTY. MANUEL J. JIMENEZ, JR., Complainant, vs. JUDGE MICHAEL M. AMDENGAN, Presiding Judge, Municipal Trial Court, Angono, Rizal, Respondent.
FACTS

Complainant, the counsel for the plaintiff in an ejectment case pending before respondent judge’s court, filed an administrative complaint. The first charge alleged gross inefficiency for the judge’s failure to resolve the ejectment case within the 30-day period mandated by the Rules on Summary Procedure. The records show the parties filed their position papers on January 4, 2010, but the judge only rendered his decision on March 3, 2010, incurring a one-month delay. The second charge alleged gross ignorance of the law for dismissing the ejectment complaint due to the plaintiff’s failure to refer the dispute to the barangay for conciliation, a ground complainant argued was erroneous.
In his Comment, respondent judge admitted the delay in resolving the case, offering no excuse but pleading for leniency due to his age and health. Regarding the dismissal on the ground of non-compliance with barangay conciliation, he argued that any error in his ruling was judicial in nature and should have been corrected through the appropriate judicial remedies, not an administrative complaint.

ISSUE

Whether respondent judge is administratively liable for (1) undue delay in rendering a decision, and (2) gross ignorance of the law for dismissing an ejectment case for lack of prior barangay conciliation.

RULING

The Supreme Court found respondent judge administratively liable only for undue delay. On the first charge, the Court affirmed that an ejectment case is governed by the mandatory 30-day period for rendition of judgment under the Rules on Summary Procedure (Rule 70, Rules of Court). The judge’s admission of a one-month delay, without a valid justification, constituted a violation of this rule and amounted to undue delay, a less serious charge under Rule 140 of the Rules of Court. The Court modified the OCA’s recommended fine, imposing a fine of P10,000 with a stern warning.
On the second charge, the Court agreed with the OCA that it was dismissible. An administrative complaint is not the proper remedy to correct a judge’s alleged erroneous application of law or procedure in a specific case, provided there is no evidence of bad faith, malice, or dishonesty. The propriety of dismissing the ejectment case for lack of prior barangay conciliation involves an exercise of judicial discretion. The aggrieved party’s correct recourse was to appeal the dismissal order. Since the error, if any, was judicial and not attended by fraud or corruption, the charge of gross ignorance of the law was dismissed for being judicial in nature.