A.M. No. MTJ-09-1743; August 3, 2010
Josephine Sarmiento and Mary Jane Mansanilla, Complainants, vs. Hon. Aznar D. Lindayag, Assisting Judge, Municipal Trial Court in Cities, City of San Jose del Monte, Bulacan, Respondent.

FACTS

The complainants were defendants in two ejectment cases filed by the Spouses Burlas concerning the same property before the same court presided by respondent Judge Aznar D. Lindayag. The first complaint was dismissed by the respondent judge in a March 14, 2000 decision, which became final. On February 2, 2002, the spouses filed a second ejectment complaint. The complainants raised the defense of res judicata. The case was submitted for decision on June 16, 2002.
Respondent judge rendered his decision on the second complaint nearly four years later, on May 31, 2006, ruling against the complainants. In their administrative complaint, the complainants charged respondent with malicious delay in the administration of justice, grave abuse of authority, and gross ignorance of the law, alleging his decision favored the plaintiffs despite lack of evidence and ignored the res judicata defense.

ISSUE

Whether respondent Judge Aznar D. Lindayag is administratively liable for undue delay in rendering a decision.

RULING

Yes, the respondent judge is administratively liable for undue delay. The Court emphasized that ejectment cases, being summary in nature, are designed for expeditious resolution to protect possession rights. The Revised Rule on Summary Procedure mandates that decisions in such cases must be rendered within thirty (30) days from receipt of the last affidavits and position papers. Respondent’s delay of close to four years was a clear violation of this rule and the constitutional mandate for speedy case disposition.
In his defense, respondent cited his dual assignments as Presiding Judge of MTC-Pandi and Assisting Judge of MTCC-San Jose del Monte, resulting in a heavy workload and poor office conditions. The Court, however, found these insufficient to exonerate him. Judicial duty requires diligence and efficient court management. If unable to comply with periods, a judge must seasonably request an extension, which respondent failed to do. His previous admonition in a prior administrative case for similar delay and a pending separate charge for inefficiency aggravated his liability. Applying Rule 140 of the Rules of Court, undue delay is a less serious charge. Considering the circumstances and his record, the Court imposed a fine of Fifteen Thousand Pesos (₱15,000.00) as recommended by the Office of the Court Administrator.