G.R. No. RTJ-03-1756; April 22, 2003
Aurora S. Gonzales, complainant, vs. Judge Vicente A. Hidalgo, Regional Trial Court, Branch 37, Manila, respondent.

FACTS

Complainant Aurora Gonzales was the prevailing party in an ejectment case that concluded with finality in the Supreme Court. For execution, the Metropolitan Trial Court (MTC) issued a writ to levy the supersedeas bond posted by the losing party’s surety, Development Insurance & Surety Corporation (DISCO). DISCO then filed a new civil case before respondent Judge Hidalgo’s court, assailing the writ and seeking an injunction. Gonzales filed an Omnibus Motion to Dismiss and a Motion to Cite for Contempt, alleging forum-shopping. After a hearing, Judge Hidalgo deemed these motions submitted for resolution.
However, without first resolving Gonzales’s pending motions, Judge Hidalgo granted DISCO’s application for a preliminary injunction, effectively halting the execution. Gonzales subsequently filed a Motion for Reconsideration of the injunction order and a Motion to Resolve Pending Incidents. Despite follow-ups, the respondent judge failed to act upon these motions, leaving the injunction in place and preventing Gonzales from enforcing her judgment for an extended period.

ISSUE

Whether respondent Judge Vicente A. Hidalgo is administratively liable for gross inefficiency due to his failure to resolve pending motions within the reglementary period.

RULING

Yes, respondent judge is administratively liable for gross inefficiency. The Court emphasized that a judge’s failure to resolve motions and incidents within prescribed periods constitutes undue delay, which erodes public faith in the judiciary. The Constitution and procedural rules mandate that motions for reconsideration be resolved within thirty days from submission. By his own admission in his Comment, Judge Hidalgo failed to comply with this mandate.
The Court rejected the judge’s proffered excuse of lack of court personnel (e.g., no clerk of court or legal researcher). Such an alleged lack is not a valid justification. The legal logic is clear: the duty to decide promptly is personal and mandatory. If a judge needs more time, the proper recourse is to request a reasonable extension from the Supreme Court, which is routinely granted for good cause. Judge Hidalgo’s failure to seek an extension and his inaction constituted a violation of Rule 3.05 of the Code of Judicial Conduct and Section 9, Rule 140 of the Rules of Court (a less serious charge of undue delay). His silence on the other unresolved motions was deemed an implied admission of the allegations. Accordingly, the Court found him guilty of gross inefficiency and imposed a fine of P11,000.00 with a stern warning.