A.M. No. RTJ-99-1494; November 29, 2000
Roman A. Villanueva, Jr., complainant, vs. Judge Apolinario F. Estoque, RTC, Branch 3, Butuan City, respondent.

FACTS

The Office of the Court Administrator received a sworn complaint against Judge Apolinario F. Estoque for Gross Ignorance of the Law, Grave Abuse of Discretion, and rendering an Unjust Decision. The complaint stemmed from his handling of a forcible entry case (Civil Case No. 236) while acting as presiding judge of the Municipal Trial Court of Nasipit. The complainant alleged that the judge violated the Rules on Summary Procedure by granting a defendant’s Motion for Extension of Time to file a position paper, which is a prohibited pleading under the rules. It was further alleged that the decision was rendered beyond the reglementary period and was contrary to the evidence.
In his Comment, respondent judge admitted granting the prohibited motion but defended his action as necessary in the interest of justice and fair play to hear both sides. He attributed any delay in decision-making to his heavy workload from being designated as acting judge in four other courts. He characterized the complaint as motivated by ill-feeling from the complainant, who lost the underlying case and was a former law school classmate.

ISSUE

Whether respondent judge is administratively liable for granting a motion for extension of time to file a position paper in a summary procedure case and for failing to decide the case within the reglementary period.

RULING

Yes, respondent judge is administratively liable. The Supreme Court found that the judge committed a clear violation of the Revised Rule on Summary Procedure. Section 19(e) explicitly prohibits motions for extension of time to file pleadings in summary proceedings. The rule is mandatory and leaves no room for discretion. The judge’s justification—that he acted for “fair play” and to hear both sides—is legally untenable. The summary procedure rules are designed for expeditious settlement, and strict compliance is required. Due process is not violated by disallowing extensions, as parties are given ample opportunity to present their evidence through their initial pleadings.
Regarding the delay, the Court acknowledged the judge’s heavy caseload but emphasized that such conditions do not excuse failure to observe mandatory periods. Judges must manage their courts efficiently to comply with reglementary deadlines. While the Court considered the judge’s explanation in mitigation, his disregard for a clear procedural rule constituted gross ignorance of the law. However, given the circumstances and his otherwise unblemished record, the penalty of removal was not deemed warranted. Instead, the Court imposed a fine of Five Thousand Pesos (P5,000.00) with a stern warning that a repetition would be dealt with more severely.