In Antonio L. Del Mundo v. Judge Lizabeth Gutierrez-Torres, the Supreme Court emphasized the critical duty of judges to resolve cases and pending matters promptly. The Court found Judge Gutierrez-Torres guilty of gross inefficiency for her failure to act on pending motions within the mandated 90-day period and for disregarding directives from the Office of the Court Administrator (OCA). This decision underscores the judiciary’s commitment to upholding the integrity of the judicial system and ensuring timely justice for all litigants. It serves as a reminder to judges of their constitutional obligation to expedite the resolution of cases, thereby maintaining public trust and confidence in the courts.

Justice Delayed, Justice Denied: When Inefficiency Undermines the Court’s Mandate

The case began with a simple ejectment action filed by Antonio L. Del Mundo against Victoriano G. Sanchez. The case, docketed as Civil Case No. 18756, was assigned to Branch 60 of the Metropolitan Trial Court (MeTC) of Mandaluyong City, presided over by Judge Lizabeth Gutierrez-Torres. Following the defendant’s Motion to Dismiss and the plaintiffs’ subsequent opposition, a series of motions were filed, including a Motion to Resolve the Motion to Dismiss and a Motion to Deposit Rentals. Despite these filings and the plaintiffs’ repeated urgings, Judge Gutierrez-Torres failed to act on the pending motions within the prescribed 90-day period. This inaction prompted Del Mundo to file an administrative complaint against the judge, alleging inefficiency and violation of the Code of Judicial Conduct.

The Office of the Court Administrator (OCA) directed Judge Gutierrez-Torres to comment on the complaint. However, she failed to respond, even after a second directive. Eventually, the OCA recommended that the Supreme Court require her to comment and explain her failure to comply with the prior directives. It was only after the Supreme Court issued a resolution directing her to comment that Judge Gutierrez-Torres finally responded. She cited a heavy caseload as justification for the delay and claimed to have believed that the complaint had been withdrawn. However, the Supreme Court found her explanation unsatisfactory, emphasizing that a judge’s duty to resolve cases promptly is a constitutional mandate.

The Supreme Court, in its decision, underscored the constitutional mandate for judges to promptly dispose of cases:

Section 15. (1) All cases or matters filed after the effectivity of this Constitution must be decided or resolved within twenty-four months from date of submission for the Supreme Court, and, unless reduced by the Supreme Court, twelve months for all lower collegiate courts, and three months for all other lower courts.

This mandate, the Court emphasized, applies not only to the final disposition of cases but also to motions and interlocutory matters. The failure to comply with this mandate constitutes a violation of the Code of Judicial Conduct, specifically Canon 1, Rule 1.02, which requires judges to administer justice without delay, and Canon 3, Rule 3.05, which mandates judges to dispose of court business promptly and decide cases within the required periods. Such violations amount to gross inefficiency, warranting administrative sanctions.

The Court noted that even if a reply to the opposition of the Motion to Dismiss, which is a prohibited pleading under Section 13 of Rule 70, was considered, the Motion to Dismiss should have been resolved within 90 days from March 26, 2003. However, Judge Gutierrez-Torres resolved the motion only on May 18, 2004, approximately eleven months beyond the reglementary period. Furthermore, the plaintiffs’ Motion to Deposit Rentals remained unaddressed. These delays, the Court held, undermined public faith in the judiciary and reinforced the perception that the wheels of justice grind slowly.

The Court also addressed the issue of respondent’s failure to submit her comment on the complaint as required by the OCA, deeming it untenable and indicative of either ignorance or insubordination. The Court clarified that a complainant’s desistance does not automatically warrant the dismissal of an administrative complaint against a judge. Judges are expected to comply with directives from the OCA, which is tasked with assisting the Supreme Court in its administrative supervision over all courts.

The Supreme Court referenced several cases to support its decision. In Pesayco v. Judge Layague, 447 SCRA 450, 463 (2004), it was held that the constitutional mandate to promptly dispose of cases applies even to motions or interlocutory matters. In Hilario v. Judge Concepcion, 327 SCRA 96, 103-104 (2000), unreasonable delay in resolving motions constitutes gross inefficiency warranting administrative sanction. Furthermore, the Supreme Court has reminded trial court judges to dispose of court business promptly, as delays undermine public faith in the judiciary, as cited in Yu-Asensi v. Judge Villanueva, 322 SCRA 255, 263 (2000).

The Supreme Court emphasized that Judge Gutierrez-Torres, as a judge of the Metropolitan Trial Court, should be well-versed in the rules governing ejectment cases, particularly Rule 70 of the Rules of Court and the Revised Rule on Summary Procedure. Section 19 of the 1991 Revised Rule on Summary Procedure and Section 13, Rule 70 of the Rules of Court prohibit the filing of a motion to dismiss in an ejectment case, except for lack of jurisdiction or failure to refer the case to the Lupon for conciliation.

The defendant’s Motion to Dismiss was based on the absence of a prior demand to pay and vacate, as required by Section 2, Rule 70 of the Rules of Court. However, the Court noted that jurisdiction over the subject matter is determined by the allegations in the complaint, not by the allegations in a motion to dismiss. Because the complaint clearly alleged that the plaintiffs had made a demand on the defendant to pay rentals and vacate the premises, the Court found that Judge Gutierrez-Torres should have easily determined the presence of jurisdiction.

In light of Judge Gutierrez-Torres’s gross inefficiency and failure to comply with OCA directives, the Supreme Court imposed a fine of Twenty Thousand Pesos (P20,000.00) and issued a stern warning against any repetition of similar acts. This ruling serves as a reminder to all judges of their duty to uphold the integrity of the judiciary by ensuring the prompt and efficient resolution of cases.

FAQs

What was the central issue in this case?	The central issue was whether Judge Gutierrez-Torres exhibited gross inefficiency by failing to act promptly on pending motions and disregarding directives from the Office of the Court Administrator (OCA).
What specific actions constituted gross inefficiency?	The judge’s failure to resolve the Motion to Dismiss and the Motion to Deposit Rentals within the mandated 90-day period, as well as her failure to respond to the OCA’s directives, were considered acts of gross inefficiency.
What is the constitutional mandate regarding the resolution of cases?	The Constitution mandates that all lower courts must decide or resolve cases within three months from the date of submission.
What provisions of the Code of Judicial Conduct were violated?	Judge Gutierrez-Torres violated Canon 1, Rule 1.02, which requires judges to administer justice without delay, and Canon 3, Rule 3.05, which mandates judges to dispose of court business promptly.
What is the role of the Office of the Court Administrator (OCA)?	The OCA assists the Supreme Court in its administrative supervision over all courts and ensures compliance with its directives.
Can a complainant’s desistance lead to the dismissal of an administrative case against a judge?	No, a complainant’s desistance does not automatically warrant the dismissal of an administrative complaint against a judge.
What is the penalty for gross inefficiency under the Rules of Court?	Under Rule 140 of the Rules of Court, as amended, gross inefficiency is classified as a less serious charge, carrying sanctions such as suspension or a fine.
What was the Supreme Court’s ruling in this case?	The Supreme Court found Judge Gutierrez-Torres guilty of gross inefficiency and fined her P20,000.00, with a stern warning against future similar acts.
Why are motions to dismiss generally prohibited in ejectment cases?	Motions to dismiss are generally prohibited in ejectment cases under the Revised Rule on Summary Procedure to expedite the proceedings, except for lack of jurisdiction or failure to comply with barangay conciliation.

This case serves as a potent reminder to all members of the judiciary of their solemn duty to administer justice promptly and efficiently. The Supreme Court’s firm stance against delays and non-compliance with administrative directives underscores its commitment to ensuring that the judicial system serves the public effectively and without undue delay. The prompt resolution of cases is not merely a procedural requirement but a fundamental aspect of justice that directly impacts the lives and well-being of litigants.

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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: ANTONIO L. DEL MUNDO v. JUDGE LIZABETH GUTIERREZ-TORRES, A.M. NO. MTJ-05-1611, September 30, 2005