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Tierra Firma Estate vs. J. Quintin, Adm. No. Mtj-02-1434

This document is a judicial decision regarding a complaint against Judge Edison F. Quintin for failing to decide a case within the required 30-day period, resulting in a delay of over 200 days. The court found the judge guilty of inefficiency and reprimanded him, emphasizing the importance of timely case resolution to maintain public confidence in the judiciary. The judge's claims of heavy caseload and other responsibilities were deemed insufficient justifications for the delay.

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0% found this document useful (0 votes)
13 views3 pages

Tierra Firma Estate vs. J. Quintin, Adm. No. Mtj-02-1434

This document is a judicial decision regarding a complaint against Judge Edison F. Quintin for failing to decide a case within the required 30-day period, resulting in a delay of over 200 days. The court found the judge guilty of inefficiency and reprimanded him, emphasizing the importance of timely case resolution to maintain public confidence in the judiciary. The judge's claims of heavy caseload and other responsibilities were deemed insufficient justifications for the delay.

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pasague.ja35
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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5/5/25, 2:38 AM A.M. No.

MTJ-02-1434

Today is Monday, May 05, 2025

Constitution Statutes Executive Issuances Judicial Issuances Other Issuances Jurisprudence International Legal Resources Legal Links

SECOND DIVISION

A.M. No. MTJ-02-1434 July 2, 2002

TIERRA FIRMA ESTATE AND DEVELOPMENT CORPORATION, complainant,


vs.
JUDGE EDISON F. QUINTIN, Presiding Judge, Metropolitan Trial Court, Branch 56, Malabon, Metro Manila,
respondent.

MENDOZA, J.:

This is a complaint filed against Judge Edison F. Quintin, Presiding Judge of the Metropolitan Trial Court, Branch 56,
Malabon, Metro Manila, for failure to decide Civil Case No. JL00-026, entitled "Tierra Firma Estate & Development
Corporation v. Consumer Commodities International, Inc.," within 30 days after it was submitted for decision, as
required under Rule 70, §9 of the Revised Rules of Civil Procedure and the Rule on Summary Procedure.

It appears that on September 14, 2000, a complaint for unlawful detainer was filed by complainant against
Consumer Commodities International, Inc. in the Metropolitan Trial Court of Malabon, Metro Manila, where it was
docketed as Civil Case No. JL00-026. After the defendant had filed its answer, the case was set for preliminary
conference on December 7, 2000. Despite due notice, the defendant did not appear. Consequently, respondent
judge considered the case submitted for decision. However, notwithstanding the motions for the early resolution of
the case filed by complainant on March 2, 2001 and March 22, 2001, judgment was not rendered in the case until
July 10, 2001. 1âwphi1.nêt

Respondent judge claims as reasons for his delay in rendering a decision in the case that he has a heavy caseload
resulting from the expanded jurisdiction of the Metropolitan Trial Courts; that he also had to preside over the
Metropolitan Trial Court of Navotas, Branch 54, as acting judge thereof since March 15, 1999; and that, as a result
of a fire which destroyed the courthouse in July 2000, he had to hold proceedings in his original station in a single
cramped room with no partitions and with the barest of facilities.

Complainant claimed in his Reply to the Comment that there are no intricate questions of fact and of law that would
justify the delay of 210 days and that respondent judge tolerated dilatory tactics by the defendant by entertaining
motions which are prohibited under Rule 70, §13 of the Revised Rules of Civil Procedure.

The Court Administrator submitted the following report on April 2, 2002:

EVALUATION: We find merit in this complaint and primarily recommend that this case be re-docketed as a
regular administrative complaint.

"Formal investigation of charges is unnecessary where the records of the case sufficiently provide basis to
determine the judge's liability or lack of it." (Montemayor vs. Collado, 107 SCRA 258)

Records show that Civil Case No. JL-00-026 for Unlawful Detainer was submitted for decision in an Order
dated December 7, 2000 and a decision was rendered thereon only on July 10, 2001, or a period of more
than 200 days after submission in violation of Sec. 11, Rule 70 of the 1997 Rules of Civil Procedure. It was
also noted that respondent entertained a prohibited pleading, i.e., motion for reconsideration, which was set
for hearing on May 4, 2001 and eventually denied on June 19, 2001, in violation of part. 3, Sec. 13 of the
same Rules.

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Failure to decide a case within the required period is not excusable and constitutes gross inefficiency.
(Ancheta v. Antonio, 231 SCRA 74)

RECOMMENDATION: ACCORDINGLY, it is respectfully recommended that:

(a) this case be RE-DOCKETED as a regular administrative matter;

(b) respondent judge be held liable for inefficiency and REPRIMANDED with a stern WARNING that a
repetition of the same or similar act(s) could be dealt with more severely.1

After a review of the records of this case, the Court finds the recommendation of the Office of the Court
Administrator to be well taken.

Actions for forcible entry and unlawful detainer are governed by the Rule on Summary Procedure, which was
designed to ensure the speedy disposition of these cases. Indeed, these cases involve perturbation of the social
order which must be restored as promptly as possible.2 For this reason, the speedy resolution of such cases is thus
deemed a matter of public policy.3

In this case, Civil Case No. JL00-026 was submitted for decision on December 7, 2000. However, respondent judge
rendered his decision only on July 10, 2001, or 215 days after the case was submitted for decision, way beyond the
30-day period provided in Rule 70, §9 of the Revised Rules of Civil Procedure. Likewise, §11 of the same rule
provides that the court shall render judgment within 30 days after receipt of the affidavits and position papers, or the
expiration of the period for filing the same.

Respondent judge blames his heavy caseload on the fact that the jurisdiction of the Metropolitan Trial Courts has
been expanded and he was an acting judge of another sala. But, as this Court has ruled in several cases, the
designation of a judge to preside over another sala is an insufficient reason to justify delay in deciding a case. This
is because he is not precluded from asking for an extension of the period within which to decide a case if this is
necessary.4 What respondent judge appears to overlook is that the delay in the disposition of the case is due in part
to the fact that he entertained motions,5 some of which are prohibited by the Rule on Summary Procedure, filed by
the defendant which further protracted the resolution of the case. As pointed out by complainant in its Motion to
Resolve filed on March 2, 2001 and Opposition to the Motion to Set for Preliminary Conference and Second Motion
to Resolve filed on March 22, 2001, the continuing delay in the resolution of the case has already caused grave
damage to it considering that the defendant continued to occupy the leased property without paying rent and the
accumulated unpaid rent has already reached more than P350,000.00, to the detriment of complainant.

What this Court said in another case is apropos:

Indeed, this Court has constantly impressed upon the judges – may it not be said without success – the need
to decide cases promptly and expeditiously, for it cannot be gainsaid that justice delayed is justice denied.
Delay in the disposition of cases undermines the people's faith and confidence in the judiciary. Hence, judges
are enjoined to decide cases with dispatch. Their failure to do so constitutes gross inefficiency and warrants
the imposition of administrative sanctions on them.6

WHEREFORE, respondent Judge Edison F. Quintin is found GUILTY of inefficiency in the disposition of Civil Case
No. JL00-026 and hereby REPRIMANDED with WARNING that repetition of a similar infraction will be dealt with
more severely.

SO ORDERED.

Bellosillo, and Corona, JJ., concur.


Quisumbing, J., abroad, on official business.

Footnotes
1 Report of the Office of the Court Administrator, pp. 2-3.

2 Uy v. Santiago, 336 SCRA 680 (2000).

3 Farrales v. Camarista, 327 SCRA 84 (2000).

4 Echaves v. Fernandez, A.M. No. RTJ-00-1596, February 19, 2002; Montes v. Bugtas, A.M. No. RTJ-01-
1627, April 17, 2001; Gallego v. Doronilla, 334 SCRA 339 (2000); Balayo v. Buban, Jr., 314 SCRA 16 (1999).

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5 Opposition to the Motion to Resolve with Motion to Set Case for Preliminary Conference, filed on March 19,
2001, and Urgent Motion For Reconsideration, filed on April 16, 2001.
6 Gil v. Janolo, Jr., 347 SCRA 6, 8-9 (2000).

The Lawphil Project - Arellano Law Foundation

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