G.R. No. A.M. No. MTJ-97-1140 March 23, 1998
United Church of Christ in the Philippines — Surigao District Conference (UCCP-SUDISCON), Duly Represented by Its Moderator Rev. Temestocles C. Onde, complainant, vs. Hon. Jose M. Garcia, Judge of the Municipal Trial Court of Tandag, Surigao del Sur, respondent.

FACTS

The complainant, United Church of Christ in the Philippines — Surigao District Conference (UCCP-SUDISCON), represented by its Moderator, Reverend Temestocles C. Onde, filed an administrative complaint against respondent Judge Jose M. Garcia of the Municipal Trial Court of Tandag, Surigao del Sur, for inefficiency and gross ignorance of the law. The charges stemmed from the judge’s handling of Civil Case No. 478, an unlawful detainer case filed by the complainant against Juan Murillo, et al., on March 11, 1994. The respondent Judge dismissed the case on July 31, 1995, for lack of jurisdiction after the defendants raised the issue of ownership. The complainant moved for reconsideration, citing Section 33(2) of Batas Pambansa Blg. 129, but the motion was denied on September 7, 1995, for being a prohibited pleading under the Rules on Summary Procedure. The complainant filed a notice of appeal on September 26, 1995, which the respondent Judge denied due course on October 18, 1995, for failure to perfect the appeal within the 15-day reglementary period under Section 2, Rule 40 of the Rules of Court. The Office of the Court Administrator (OCA) found that the respondent Judge was remiss in observing the summary procedure for ejectment cases, noting significant delays in the proceedings. The OCA initially recommended a fine of P5,000.00 against the judge and an admonition to the complainant’s counsel, but upon re-evaluation, maintained its recommendation.

ISSUE

Whether respondent Judge Jose M. Garcia is administratively liable for undue delay in resolving an unlawful detainer case and for gross ignorance of the law in his handling of the case’s procedural aspects.

RULING

The Supreme Court found respondent Judge Jose M. Garcia guilty of undue delay in the disposition of the ejectment case. The Court accepted the OCA’s findings that the judge failed to comply with the summary procedure timeline, resulting in a resolution more than a year after filing, contrary to the required speedy disposition. The Court also noted the judge’s erroneous reliance on outdated jurisprudence. However, the Court reduced the recommended fine from P5,000.00 to P2,000.00, to be deducted from his retirement and other benefits. The Court declined to admonish the complainant’s counsel, Atty. Elmer T. Paniamogan, as he was not a party to the administrative case and any recourse against him should follow the proper procedural rules.