Farrales v. Camarista (A.M. No. MTJ-99-1184, March 02, 2000)

Petitioners: AMPARO S. FARRALES AND ATTY. RAUL S. SISON
Respondent: JUDGE RUBY B. CAMARISTA

Topic: Revised Rule on Summary Proceedings (Section 10 and 8); Erroneous Application of P.D. 1508

Doctrine: It is thus very clear that the period for a rendition of judgment in cases falling under the summary procedure is thirty days. This is in keeping with the spirit of the rule which aims to achieve an expeditious and inexpensive determination of the cases falling thereunder.

Recit-ready: There were two civil cases which were remained unsolved because the respondent Judge referred them to the barangay for conciliation instead of actually deciding on the case. The complainants contend that the respondent Judge lacks knowledge on the Revised Rule on Summary Procedure and questioned the acts of the judge on referring the case to the barangay level when the parties live in barangays of different cities or municipalities. The respondent Judge averred that she referred the cases to the barangay even when it is not necessary. However, she anchors he act on Section 2 of P.D. 1508 and stressed that she referred the case to the lupon of barangay where the realty subject is located. The crux of the matter is respondent Judge's violation of the Revised Rule on Summary Procedure and her erroneous application of P.D. 1508.

The Supreme Court declared Judge Camarista GUILTY of gross incompetence, gross inefficiency, and ignorance of law. The period for rendition of judgment in cases falling under the summary procedure is 30 days. The jurisprudential direction consistently taken by the Court adheres to the rule that failure to decide a case within the required period is not an excuse and constitutes gross inefficiency. The requirement under the Rule on Summary Procedure was intended for the expeditious resolution of cases falling thereunder. 

Facts: The complainants, in this case, through a verified complaint, charged the respondent with gross incompetence, gross inefficiency, and ignorance of the law with regard to two civil cases.

In the first case, the respondent Judge denied the complainant's motion to set aside the order referring the case for conciliation to the barangay and denied the complainant's motion to set the case for a preliminary conference. Subsequently, the complainants submitted themselves to conciliation but no settlement was reached. The case was deemed submitted for a decision since there are no clarificatory hearings but the case was remained undecided despite repeated follow-ups.

In the second case, the respondent Judge directed the parties to file their position papers notwithstanding the lapse of 2 years and a month from service of summon. After the lapse of 30 days from submission of the position papers, and there being no decision rendered by respondent Judge, the complainant wrote to the respondent Judge requesting that a decision be rendered but to no avail because the case remained unresolved.

Complainants contend that the delay in disposition was a result of the Judge's lack of basic knowledge on the 1991 Revised Rule on Summary Procedure and/or her ignorance of the law. They also questioned the respondent Judge's act of referring the case to the barangay level for conciliation when parties reside in barangays of different cities/municipalities. The complainants then informed the Court that despite the filing of the administrative complaint, no decision has been rendered to the two civil cases.

Respondent Judge submits that she cannot be administratively liable because both cases were not originally assigned to her. She claims that her court was transferred in an untimely and abrupt manner. She said that even when referring the case to the barangay level is not necessary, the last paragraph of Section 2 of P.D. 1508 gives the Court discretion to refer the case to the lupon for amicable settlement although it may not fall within the authority of the lupon.

Issue/s:

1. Whether or not Judge Camarista violated 1991 Revised Rule on Summary Procedure. -> YES
2. Whether or not Judge Camarista erroneously applied the Katarungang Pambarangay Law. -> YES

Held:

1. Yes, Judge Camarista violated the 1991 Revised Rule on Summary Procedure. The Rule clearly and undoubtedly provided for the period within which the judgment should be rendered. Section 10 of the Rule on Summary Procedure provides that the judgment should be rendered within 30 days. Section 8 of the same Rule provides that absent the need of further proceedings, the judgment shall be rendered within 30 days from the issuance of the order. In the case at bar, Sison only received the decisions for both cases only after 2 years from submission of the last affidavits and position papers therein.
2. Yes, Camarista erroneously applied the Katarungang Pambarangay Law. She anchors her act on Section 2 thereof. The last paragraph of such provision apparently gives the Court discretion to refer the case to the lupon for amicable settlement although it may not fall within the authority of the lupon (such as the civil cases subject of this administrative proceeding). However, referring the subject civil cases to the lupon is silently an unsound exercise of discretion considering that the matter falls under the Rule on Summary Procedure. The Rule on Summary Procedure was promulgated for the purpose of achieving "an expeditious and inexpensive determination of cases." The fact that unlawful detainer cases fall under the summary procedure, speedy resolution thereof is thus deemed a matter of public policy. Thus, the Rule frowns upon delays. Manifestly, respondent's act of referring the subject cases to the lupon subverts the very nature of the Rule and defeats its objective of expediting the adjudication thereof.

Provisions:

SEC. 10. Rendition of judgment. 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.

However, should the court find it necessary to clarify certain material facts, it may, during the said period, issue an order specifying the matters to be clarified, and require the parties to submit affidavits or other evidence on the said matters within ten (10) days from receipt of said order. Judgment shall be rendered within fifteen (15) days after the receipt of the last clarificatory affidavits, or the expiration of the period for filing the same.

The court shall not resort to the clarificatory procedure to gain time for the rendition of the judgment.

SEC. 8. Record of preliminary conference.

c) Whether, on the basis of the pleadings and the stipulations and admissions made by the parties, judgment may be rendered without the need of further proceedings, in which event the judgment shall be rendered within thirty (30) days from issuance of the order;