The Supreme Court found Judge Romulo G. Carteciano, a retired judge from the Municipal Trial Court of Los Baños, Laguna, guilty of gross inefficiency for failing to decide an ejectment case within the mandated 30-day period. Despite the explanation of a computer breakdown, the Court imposed a fine of P1,000.00, to be deducted from his retirement benefits, highlighting the importance of prompt disposition of cases. This decision emphasizes that judges must prioritize efficiency and explore alternative means to fulfill their duties even in the face of logistical challenges.

Justice Delayed: Examining a Judge’s Accountability in Ejectment Case Decision

This case arose from a complaint filed by Atty. Joselito A. Oliveros, counsel for the plaintiff in an ejectment case (Custer S. Oliveros v. Yolanda C. Corvera, et al., Civil Case No. 2167). Oliveros alleged that Judge Romulo G. Carteciano, presiding judge of the Municipal Trial Court of Los Baños, Laguna, committed “gross neglect of duty” by failing to render a decision within the 30-day period prescribed by the Revised Rule on Summary Procedure. The ejectment case was submitted for decision in March 2000, but as of the complaint date in March 2001, no decision had been issued, despite repeated motions and follow-ups. This delay prompted the administrative complaint against Judge Carteciano.

In his defense, Judge Carteciano admitted to the delay but attributed it to a breakdown in his computer, which he relied upon for preparing court decisions. He stated that the court used a second-hand computer and printer rented at his personal expense. Despite the technical difficulties, he submitted that the decision in Civil Case No. 2167 was eventually rendered on July 18, 2001. However, the Court Administrator found the explanation to be “flimsy,” suggesting that the judge could have used a manual typewriter as an alternative.

The Revised Rule on Summary Procedure clearly outlines the timelines for submitting affidavits, position papers, and rendering judgments. Section 10 specifically states,

“Within 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.”

This mandate underscores the importance of speedy resolution in summary proceedings. In this instance, the case was deemed submitted for decision on March 16, 2000, giving Judge Carteciano a deadline of April 15, 2000, to issue a ruling.

The Supreme Court agreed with the Court Administrator’s assessment that Judge Carteciano’s explanation was insufficient. Even with the computer malfunction, alternative methods existed, such as using a manual typewriter or requesting an extension of time from the Court. Failing to explore these alternatives constituted a violation of judicial responsibility. The Court highlighted that a simple breakdown in equipment doesn’t excuse neglecting such responsibility to render the appropriate judgement.

This situation violated Canon 3, Rule 3.05 of the Code of Judicial Conduct, which emphasizes the need for judges to dispose of court business promptly. This section stipulates that “A judge shall dispose of the court’s business promptly and decide cases within the periods fixed by law.” By failing to issue a decision within the 30-day period and not seeking an extension or utilizing alternative resources for generating this decision, Judge Carteciano was clearly found responsible.

The court ultimately deemed Judge Carteciano to be in gross violation of the code of conduct set out for judges. His action constitutes a clear and unforced error on his part as many other options could have been implemented and were at his disposal during that time. Ultimately a 1,000-peso fine was applied to his retirement benefits as punitive actions, setting precedent for judicial protocol moving forward in this area of practice.

Below is a summarization of the core events.

Event	Date
Case Submitted for Decision	March 16, 2000
Mandatory Deadline for Decision	April 15, 2000
Decision Rendered	July 18, 2001

FAQs

What was the key issue in this case?	The key issue was whether Judge Carteciano was negligent in his duty by failing to render a decision in an ejectment case within the prescribed 30-day period as required by the Revised Rule on Summary Procedure.
What was Judge Carteciano’s explanation for the delay?	Judge Carteciano attributed the delay to a breakdown in his computer, which he relied upon for preparing court decisions, and noted that the court’s equipment was rented at his personal expense.
What alternative could he have employed?	He could have written his decisions manually, on the available type-writer he could access for situations like this, or petitioned the courts to be given and provided better or extended infrastructure,
What Rule was used as legal basis?	The Supreme Court based its ruling on the Revised Rule on Summary Procedure, specifically Section 10, which mandates a 30-day period for rendering judgment. Also it highlights, Canon 3, Rule 3.05 of the Code of Judicial Conduct which says a judge shall preside and rule on issues at prompt disposition.
What was the Court Administrator’s opinion?	The Court Administrator found Judge Carteciano’s explanation “flimsy,” suggesting he could have used a manual typewriter instead.
What Canon of the Code of Judicial Conduct did Judge Carteciano violate?	Judge Carteciano violated Canon 3, Rule 3.05 of the Code of Judicial Conduct, which requires judges to dispose of court business promptly.
What was the penalty imposed on Judge Carteciano?	Judge Carteciano was fined P1,000.00, which was to be deducted from his retirement benefits.
On what date did Judge Carteciano retire?	Judge Carteciano retired from service on August 29, 2001.

This case underscores the judiciary’s commitment to efficiency and accountability. While technological difficulties may arise, judges are expected to explore alternative methods or seek extensions to ensure timely justice. This ruling sets a precedent for addressing delays in judicial proceedings and reinforces the importance of adhering to the Code of Judicial Conduct.

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: ATTY. JOSELITO A. OLIVEROS VS. JUDGE ROMULO G. CARTECIANO (RET.), A.M. No. MTJ-02-1409, April 05, 2002