The Supreme Court held Judge Mary Jocylen G. Regencia administratively liable for undue delay in rendering a decision in an ejectment case, highlighting the importance of prompt disposition of cases and adherence to the Rules of Summary Procedure. The Court emphasized that judges must resolve cases within the mandated periods and that failure to do so without justifiable reason constitutes a violation of judicial duty. This ruling underscores the judiciary’s commitment to timely justice and serves as a warning against inefficiency and neglect of duty by judges.

Justice Delayed: When an Ejectment Case Languished for Over a Decade

This case arose from a complaint filed by Gershon N. Dulang against Judge Mary Jocylen G. Regencia of the Municipal Circuit Trial Court (MCTC) of Asturias-Balamban, Cebu, citing gross inefficiency, gross ignorance of the law, and other serious charges. The core issue stemmed from the handling of an ejectment case, Civil Case No. 212-B, which had been pending before the MCTC for over a decade. Dulang alleged that Judge Regencia failed to resolve the case with due diligence, rendering a decision only after an unreasonable delay.

The facts reveal that the ejectment case was filed on February 2, 2000, and submitted for resolution on October 17, 2008. However, Judge Regencia issued a judgment dismissing the case only on February 18, 2011, more than eleven years after its initial filing. Dulang further contended that even after he filed a notice of appeal, Judge Regencia issued an order directing the postmaster to certify Dulang’s receipt of the judgment copy, which he argued was beyond her jurisdiction and prejudicial to his case.

In her defense, Judge Regencia claimed that the delay was due to a related case pending before the Regional Trial Court (RTC) of Toledo City and that she only assumed her post in November 2002, presiding over the MCTC from November 15, 2007. She also justified the post-appeal order as necessary to determine the timeliness of Dulang’s appeal due to the defendant’s opposition. The Office of the Court Administrator (OCA) investigated the matter and found Judge Regencia administratively liable for undue delay in rendering a decision, recommending a fine of P20,000.00. The OCA found no merit in Judge Regencia’s claim of partiality against the investigating judge and disregarded the subsequent death of Dulang, asserting that it did not automatically warrant the dismissal of the administrative case.

The Supreme Court’s analysis hinged on the judge’s failure to comply with the mandated timelines for resolving cases. The Court cited Rule 3.05, Canon 3 of the Code of Judicial Conduct, which requires judges to “dispose of the court’s business promptly and decide cases within the required periods.” Similarly, Section 5, Canon 6 of the New Code of Judicial Conduct for the Philippine Judiciary emphasizes that “[j]udges shall perform all judicial duties, including the delivery of reserved decisions, efficiently, fairly, and with reasonable promptness.” These provisions underscore the judiciary’s emphasis on efficiency and timely justice.

A judge shall dispose of the court’s business promptly and decide cases within the required periods

The Supreme Court considered the nature of ejectment cases, which are governed by the Rules of Summary Procedure. Section 10 of the Revised Rules on Summary Procedure prescribes a period of thirty (30) days from the submission of the last affidavit or position paper within which a decision must be issued. Despite this clear mandate, Judge Regencia took approximately two years and four months to render judgment after the case was submitted for resolution. The Court acknowledged that extensions may be granted for justifiable reasons but found no such justification in Judge Regencia’s case, thereby affirming her administrative liability for undue delay.

The Supreme Court also addressed Judge Regencia’s attempt to justify the delay by citing a pending case in the Toledo RTC and an alleged agreement between the parties to suspend proceedings. The Court found these justifications to be without merit, concurring with the OCA’s assessment that there was neither a prejudicial question nor an agreement warranting substantial delays. This attempt to mislead the Court was deemed deplorable and further aggravated her misconduct. Undue delay in rendering a decision is classified as a less serious charge, with penalties ranging from suspension to a fine.

In determining the appropriate penalty, the Court considered Judge Regencia’s prior administrative liability for gross inefficiency. In *Tam v. Judge Regencia*, she was previously fined P5,000.00 and warned against similar offenses. The Court also took note of her length of service, not as a mitigating factor, but as an indication that she should have been well aware of the expeditious nature of summary proceedings like ejectment cases. Consequently, the Court deemed a fine of P40,000.00, instead of suspension, as the appropriate penalty for Judge Regencia’s misconduct. This decision reinforces the principle that judges are expected to uphold the standards of judicial conduct and ensure the timely resolution of cases.

FAQs

What was the key issue in this case?	The key issue was whether Judge Regencia was administratively liable for undue delay in rendering a decision in an ejectment case that had been pending for over a decade.
What is the prescribed period for deciding an ejectment case?	According to the Rules of Summary Procedure, a decision in an ejectment case must be issued within 30 days from the submission of the last affidavit or position paper.
What was Judge Regencia’s defense for the delay?	Judge Regencia claimed the delay was due to a related case in the RTC and an alleged agreement to suspend proceedings, but these claims were found to be without merit.
What did the Supreme Court cite as the basis for holding Judge Regencia liable?	The Court cited Rule 3.05, Canon 3 of the Code of Judicial Conduct and Section 5, Canon 6 of the New Code of Judicial Conduct, emphasizing the duty of judges to dispose of court business promptly.
What penalty was imposed on Judge Regencia?	The Supreme Court imposed a fine of P40,000.00 on Judge Regencia and sternly warned her against future similar acts.
Why was Judge Regencia not suspended?	The Court considered the circumstances, including her prior administrative liability, her attempt to mislead the Court, and her length of service, leading to the imposition of a fine instead of suspension.
Was the death of the complainant relevant to the case’s resolution?	No, the OCA and the Supreme Court both held that the death of the complainant did not automatically result in the dismissal of the administrative complaint.
What constitutes a valid justification for delaying a decision?	Valid justifications may include complex legal issues requiring thorough analysis or circumstances beyond the judge’s control that impede the timely disposition of the case.
What is the significance of this case for judges in the Philippines?	This case emphasizes the importance of adhering to mandated timelines for resolving cases and serves as a reminder of the consequences of undue delay and inefficiency in judicial duties.

In conclusion, the Supreme Court’s decision in this case serves as a stern reminder to judges of their duty to administer justice promptly and efficiently. Undue delay in rendering decisions not only prejudices the litigants but also undermines public trust in the judiciary. The imposition of a substantial fine on Judge Regencia underscores the Court’s commitment to upholding the standards of judicial conduct and ensuring the timely resolution of cases.

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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: Gershon N. Dulang v. Judge Mary Jocylen G. Regencia, A.M. No. MTJ-14-1841, June 02, 2014