In Amparo S. Farrales and Atty. Raul S. Sison vs. Judge Ruby B. Camarista, the Supreme Court held Judge Camarista liable for gross incompetence and inefficiency due to significant delays in resolving ejectment cases under the Rule on Summary Procedure. The Court emphasized that judges must decide cases promptly within the periods fixed by law to maintain public faith in the judiciary. This ruling underscores the importance of judicial efficiency and adherence to procedural rules for the timely delivery of justice.

Justice Delayed? Examining a Judge’s Duty to Expedite Case Resolutions

This case arose from a complaint filed by Amparo S. Farrales and her counsel, Atty. Raul S. Sison, against Judge Ruby B. Camarista, concerning two civil cases for ejectment/unlawful detainer: Civil Case No. 144411-CV and Civil Case No. 144414-CV. The complainants alleged that Judge Camarista demonstrated gross incompetence, gross inefficiency, and ignorance of the law due to the prolonged delays in the disposition of these cases. The heart of the issue was whether Judge Camarista violated the 1991 Revised Rule on Summary Procedure and erroneously applied the Katarungang Pambarangay Law, leading to undue delays in resolving the cases.

The factual background reveals that the cases were filed in June 1994 and raffled to Branch I, Metropolitan Trial Court, Manila, presided over by Judge Camarista. In Civil Case No. 144411-CV, despite the defendant filing a responsive pleading, Judge Camarista motu proprio referred the case for conciliation to the barangay chairman in January 1995. The case remained uncalendared for hearing for an entire year, and even after the parties submitted themselves to conciliation without reaching a settlement, the case remained undecided for an extended period. Similarly, in Civil Case No. 144414-CV, Judge Camarista referred the case to the barangay for conciliation despite arguments that the parties resided in different cities/municipalities, further delaying the proceedings.

Complainants argued that Judge Camarista’s actions revealed a lack of basic knowledge of the 1991 Revised Rule on Summary Procedure and ignorance of the law. They specifically questioned the referral of the cases to the barangay level for conciliation when the parties resided in barangays of different cities/municipalities. In response, Judge Camarista contended that the cases were reassigned to her sala and that she referred the cases to the lupon of the barangay where the realty was located, following Presidential Decree No. 1508 and the Local Government Code of 1991. However, the Supreme Court found these justifications unpersuasive.

The Supreme Court emphasized the mandatory nature of the time frames prescribed in the Rule on Summary Procedure, specifically Section 10, which states:

SEC. 10. Rendition of judgment.ÑWithin thirty (30) days after receipt of the last affidavits and position papers, or the expiration of the period for filing the same, the court shall render judgment.

The Court found that Judge Camarista failed to comply with this provision, as the decisions in both cases were significantly delayed beyond the prescribed thirty-day period. This delay, the Court held, constituted gross inefficiency, which is not excusable. Building on this principle, the Supreme Court has consistently held that failure to decide a case within the required period is not excusable and constitutes gross inefficiency, as seen in cases like Abarquez vs. Rebosura (285 SCRA 109 [1998]).

The Court also addressed the erroneous application of the Katarungang Pambarangay Law. While Section 408 of the Local Government Code of 1991 grants courts the discretion to refer cases to the lupon for amicable settlement, the Supreme Court found that Judge Camarista’s exercise of this discretion was unsound, given that the cases fell under the Rule on Summary Procedure. The Court cited Gachon vs. Devera, Jr. (274 SCRA 540 [1997]), which highlighted that the Rule on Summary Procedure aims for “an expeditious and inexpensive determination of cases,” and that speedy resolution is a matter of public policy.

Moreover, the Court noted that the preliminary conference under Sections 7 and 8 of the Rule on Summary Procedure already serves the purpose of a possible amicable settlement. Therefore, referring the cases to the lupon was deemed a superfluous step that subverted the nature of the Rule and defeated its objective of expediting adjudication. This approach contrasts with the intent of the Rule, which seeks to streamline the litigation process and ensure timely resolution of cases.

The Supreme Court also addressed the affidavit of desistance submitted by the complainants. The Court stated that such an affidavit does not divest it of its jurisdiction to investigate and ascertain the truth of the matter alleged in the complaints against the respondent. The Court cited Rogue vs. Grimaldo (260 SCRA 1 [1996]) and Ca–a vs. Santos (234 SCRA 17 [1994]) to emphasize that the Court has an interest in the conduct of the officials and employees of the judiciary and that its efforts to improve the delivery of justice cannot be frustrated by private arrangements of the parties. Therefore, the affidavit of desistance did not absolve Judge Camarista of administrative liability.

Ultimately, the Supreme Court found Judge Ruby B. Camarista guilty of gross incompetence, gross inefficiency, and ignorance of the law. The Court ordered her to pay a fine of Ten Thousand Pesos (P10,000.00) and warned that future similar acts would be dealt with more severely. This decision serves as a reminder to judges of their duty to administer justice impartially and without delay. It also underscores the importance of adhering to procedural rules and maintaining professional competence to ensure the efficient and timely resolution of cases.

FAQs

What was the key issue in this case?	The key issue was whether Judge Camarista was liable for gross incompetence, gross inefficiency, and ignorance of the law due to delays in resolving ejectment cases under the Rule on Summary Procedure. The complainants argued that the judge’s actions, including referring cases to the barangay level and failing to render timely decisions, violated procedural rules.
What is the Rule on Summary Procedure?	The Rule on Summary Procedure is designed to achieve an expeditious and inexpensive determination of cases, particularly those involving small claims and ejectment actions. It sets specific time frames for various stages of the proceedings, including the rendition of judgment.
Why did the court find the judge guilty?	The court found Judge Camarista guilty because she failed to render decisions within the prescribed thirty-day period under the Rule on Summary Procedure. Her justifications for the delay, such as the reassignment of cases and the conditions of her court, were deemed unpersuasive.
What is the Katarungang Pambarangay Law?	The Katarungang Pambarangay Law (Presidential Decree No. 1508 and Section 408 of the Local Government Code of 1991) allows for amicable settlement of disputes at the barangay level. While courts have discretion to refer cases to the lupon, this discretion should be exercised judiciously, especially in cases covered by the Rule on Summary Procedure.
Was the judge’s referral of the cases to the barangay proper?	The court found that the referral to the barangay was an unsound exercise of discretion, given that the cases fell under the Rule on Summary Procedure. The preliminary conference already served the purpose of possible amicable settlement.
What was the effect of the affidavit of desistance?	The affidavit of desistance submitted by the complainants did not divest the Supreme Court of its jurisdiction to investigate the allegations against the judge. The Court’s interest in maintaining the integrity of the judiciary supersedes private arrangements between parties.
What was the penalty imposed on the judge?	Judge Camarista was ordered to pay a fine of Ten Thousand Pesos (P10,000.00). She was also warned that future similar acts would be dealt with more severely.
What is the significance of this ruling?	This ruling underscores the importance of judicial efficiency and adherence to procedural rules for the timely delivery of justice. It serves as a reminder to judges of their duty to administer justice impartially and without delay.

In conclusion, the Supreme Court’s decision in Farrales vs. Camarista reinforces the principle that judges must adhere to procedural rules and render timely decisions to uphold public faith in the judiciary. The case highlights the importance of judicial efficiency and the need for judges to exercise their discretion judiciously.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: AMPARO S. FARRALES AND ATTY. RAUL S. SISON VS. JUDGE RUBY B. CAMARISTA, A.M. No. MTJ-99-1184, March 02, 2000