The Supreme Court of the Philippines has made it clear: judges must decide cases promptly. Failure to do so undermines public trust and can result in administrative sanctions. This case underscores the importance of timely justice and serves as a reminder that delays can have significant consequences for all parties involved.

Justice Delayed, Justice Denied: Did the Judge’s Hesitation Harm the Plaintiff?

This case, Bonifacio Law Office v. Judge Reynaldo B. Bellosillo, revolves around a complaint filed against Judge Reynaldo B. Bellosillo for allegedly delaying the resolution of an ejectment case. The Bonifacio Law Office, representing the complainant, argued that Judge Bellosillo’s actions demonstrated ignorance of the law, grave abuse of discretion, and partiality. The central issue was whether Judge Bellosillo’s handling of the case, specifically his referral back to the barangay (local community mediation body) and subsequent delays in rendering judgment, constituted a violation of judicial duties.

The complainant, Atty. Ricardo M. Salomon Jr., initially filed an ejectment case against Spouses Severino Fulgencio. He alleged that the matter had already been referred to the barangay, attaching a Certification to File Action. However, Judge Bellosillo referred the case back to the barangay for conciliation, which the complainant protested. The complainant then filed a Notice to Withdraw Complaint and later a Notice of Dismissal, both of which were initially unacted upon. Summons were served on the defendants a year after the complaint was filed, and when they failed to answer, the complainant’s Motion to Render Judgment was met with a request for comment from the defendants, rather than a judgment.

The Office of the Court Administrator (OCA) evaluated the complaint and found merit in some of the charges, particularly regarding the judge’s disregard of the Rules on Summary Procedure. The OCA recommended a fine for the judge. The Supreme Court partly agreed with the OCA’s findings, differing on the issue of the barangay proceedings but concurring on the violation of the Rules on Summary Procedure.

The Supreme Court delved into the issue of the barangay conciliation process. The Court found that the Certification to File Action was improperly and prematurely issued, given that no genuine effort was made to settle before the Pangkat ng Tagapagkasundo. The Court quoted Section 410 (b) of the Local Government Code:

“Mediation by lupon chairman. – Upon receipt of the complaint, the lupon chairman shall within the next working day summon the respondent(s), with notice to the complainant(s) for them and their witnesses to appear before him for a mediation of their conflicting interests. If he fails in his mediation effort within fifteen (15) days from the first meeting of the parties before him, he shall forthwith set a date for the constitution of the pangkat in accordance with the provisions of this Chapter.”

The Court also cited Administrative Circular No. 14-93, which provides guidelines for trial court judges regarding cases coming from the barangays, emphasizing the need for careful scrutiny of compliance with prior conciliation procedures. In essence, the Supreme Court held that the judge was not incorrect in remanding the case to the barangay for completion of the mandated proceedings.

Building on this principle, the Supreme Court then addressed the Motion to Render Judgement. The Court found that the judge erred by calling a preliminary conference and directing the defendants to submit their comment instead of rendering judgement as required by the Rules of Summary Procedure. The Rules mandate the rendition of judgment when the defendant fails to answer within the prescribed period.

“Sec. 6. Effect of failure to answer. – Should the defendant fail to answer the complaint within the period above provided, the court, motu proprio, or on motion of the plaintiff, shall render judgment as may be warranted by the facts alleged in the complaint and limited to what is prayed for therein x x x.

Furthermore, the Court noted the delay in rendering judgment. The judge only rendered judgment almost a year after the case had been deemed submitted for resolution. This delay was deemed unacceptable, as it undermined the people’s faith in the judiciary.

The Supreme Court emphasized that undue delay in rendering a decision constitutes a less serious charge under Section 9, Rule 140 of the Rules of Court, resulting in potential suspension or a fine. Considering the absence of malice or corrupt motives, and the judge’s resignation, the Court ordered the judge to pay a fine of P11,000 to be taken from his retirement benefits.

FAQs

What was the key issue in this case?	The key issue was whether Judge Bellosillo’s handling of the ejectment case, specifically his referral back to the barangay and subsequent delays in rendering judgment, constituted a violation of judicial duties. The Supreme Court focused on whether the judge followed the Rules on Summary Procedure and if his actions caused undue delay.
What is the significance of the barangay conciliation process?	The barangay conciliation process is a mandatory pre-condition to judicial action in the Philippines. It aims to promote amicable settlement of disputes at the local level and decongest court dockets.
What are the Rules on Summary Procedure?	The Rules on Summary Procedure are a set of rules designed to expedite the resolution of certain cases, including ejectment cases. They impose strict deadlines and limit the allowable procedures to ensure swift justice.
What does it mean to render judgment motu proprio?	Motu proprio means that the court can act on its own initiative, without a motion from either party. In the context of the Rules on Summary Procedure, the court should render judgment on its own if the defendant fails to answer the complaint on time.
What is the penalty for undue delay in rendering a decision?	Under Section 9, Rule 140 of the Rules of Court, undue delay in rendering a decision constitutes a less serious charge. The penalty can be suspension from office or a fine.
Why was the judge fined instead of suspended?	The Supreme Court considered the absence of malice or corrupt motives on the part of the judge, as well as his resignation from the service. These factors mitigated the penalty.
What is the implication of this case for litigants?	This case reinforces the right of litigants to a timely resolution of their cases. It highlights the importance of judges adhering to procedural rules and avoiding unnecessary delays.
How does this case affect judges in the Philippines?	This case serves as a reminder to judges of their duty to decide cases promptly and in accordance with the law. It emphasizes that failure to do so can result in administrative sanctions.
What if the judge believed the barangay process was not completed properly?	The Supreme Court agreed that the judge acted correctly in initially remanding the case to the barangay, finding that the Certification to File Action was improperly issued. The error occurred later when the judge delayed the judgment.
What specific action by the judge was considered a violation?	The judge violated the Rules on Summary Procedure when, after the defendant failed to answer, he called for a preliminary conference and asked for comments instead of immediately rendering a judgment based on the facts presented in the complaint.

This case underscores the judiciary’s commitment to upholding the principles of timely justice and accountability. Judges are expected to adhere to procedural rules, and delays in rendering decisions can have serious consequences. The Supreme Court’s decision serves as a reminder of the importance of efficient and effective administration of justice in the Philippines.

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: Bonifacio Law Office v. Bellosillo, A.M. No. MTJ-00-1308, December 16, 2002