EVANGELINA C. SAMSON, COMPLAINANT, VS. JUDGE JULES A. MEJIA, RESPONDENT.

Samson versus Mejia

The Case

This is an administrative case brought by Evangelina C. Samson against Judge Jules A. Mejia, the presiding judge of a Regional Trial Court branch in Alaminos, Pangasinan. The complainant was the defendant in a civil case for annulment of contracts pending before the respondent's sala, and she charged him with gross misconduct for failing to decide that case within the period fixed by law. The case matters because it is the Supreme Court's clean statement of a judge's constitutional and ethical duty to decide cases promptly, and of how a violation of that duty is classified and penalized under the Revised Rules of Court.

Procedural History

The complainant filed an affidavit-complaint for gross misconduct against the respondent judge. The respondent filed his comment, admitting that there was delay but denying that it was intentional. The Office of the Court Administrator evaluated the records, found merit in the complaint, and recommended that the matter be re-docketed as a regular administrative complaint and that the respondent be held liable for gross inefficiency and fined five thousand pesos, with a stern warning. By a Resolution of the Supreme Court, both parties were directed to file their manifestations, and both did so, submitting the case for decision based on the pleadings. The case was thus resolved by the Supreme Court as an original administrative proceeding, not as an appeal from any lower court.

Facts

Evangelina Samson was the defendant in a civil case for annulment of contracts pending before the respondent's court. On March 29, 2000, the respondent ordered the parties to submit their respective memoranda within thirty days. The complainant alleged that the case was deemed submitted for decision on April 26, 2000, and that four months passed without a decision. She filed three motions for resolution, dated August 18, 2000, November 3, 2000, and January 9, 2001. When she later went to his office to plead for early disposition, the respondent ignored her plea and suggested that she settle the case amicably with the plaintiffs, which convinced her that he was withholding his decision to pressure her into a compromise.

In his comment, the respondent admitted the delay but denied any intentional favor to either party. He explained that on July 10, 2000, he issued an order on the admissibility of the evidence, and that he waited for the comment of the intervenor after ordering the intervention expunged, so that in his view the case was submitted for decision only in September 2000. He also cited the untimely death of his daughter, his designation as acting presiding judge of another branch in Iba, Zambales, and a letter from one of the plaintiffs requesting certain forms.

The records showed that the respondent rendered his decision in the civil case only on December 11, 2001. Measured from the correct date of submission, the Court found a delay of one year and more than seven months.

Issues

• Whether or not the respondent judge is liable for undue delay in rendering a decision in the civil case pending before his court.
• Whether or not the respondent's explanations, namely the death of his daughter, his designation as acting presiding judge of another branch, and the letter-request of a plaintiff, excuse or mitigate his liability.
• Whether or not the offense is a less serious charge under the Revised Rules of Court, and what penalty should be imposed.

Applicable Provisions

Article Eight, Section Fifteen, paragraph two of the Constitution provides:

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 fixes the three-month period for lower courts within which the respondent was bound to decide the civil case.

Administrative Circular Number Twenty-Eight defines when a case is deemed submitted for decision:

A case is considered submitted for decision upon the admission of the evidence of the parties at the termination of the trial. The ninety-day period for deciding the case shall commence to run from submission of the case for decision without memoranda; in case the court requires or allows its filing, the case shall be considered submitted for decision upon the filing of the last memorandum or upon the expiration of the period to do so, whichever is earlier.

This is the rule the Court applied to fix the date of submission and to measure the delay.

Section Nine, Rule One Hundred Forty of the Revised Rules of Court provides:

Less serious charges include: 1. Undue delay in rendering a decision or order, or in transmitting the records of a case.

This classifies the respondent's offense as a less serious charge.

Section Eleven, paragraph B of the same Rule provides:

If the respondent is guilty of a less serious charge, any of the following sanctions shall be imposed: 1. Suspension from office without salary and other benefits for not less than one month nor more than three months; or 2. A fine of more than ten thousand pesos but not exceeding twenty thousand pesos.

This supplies the range of penalties from which the Court drew the fine it imposed.

Ruling

On the first issue, the Court held that the respondent was liable for undue delay. Applying Administrative Circular Number Twenty-Eight, since the respondent had ordered the parties to submit memoranda within thirty days, the case was deemed submitted for decision upon the expiration of that period, on April 28, 2000. The decision was rendered only on December 11, 2001, a delay of one year and more than seven months. The Court stressed that the Code of Judicial Conduct mandates judges to dispose of the court's business promptly and to decide cases within the required periods, and that failure to do so violates a litigant's right to speedy disposition of his case and undermines the people's faith and confidence in the judiciary.

On the second issue, the Court found the respondent's explanations lacking in merit. Even accepting his claim that the case was submitted in September 2000, there was still delay. The Court commiserated with him over the death of his daughter but held that this fact, while mitigating, could not completely exculpate him; he could have asked for an extension of the period to decide, or gone on leave during his mourning. The letter-request of a plaintiff could not justify delay, and neither could his designation as acting presiding judge of another branch.

On the third issue, the Court held that while there was no evidence that the respondent purposely withheld his decision to favor the opposing party, his inaction constituted undue delay in rendering a decision, a less serious charge under Section Nine, Rule One Hundred Forty. Accordingly, the Court imposed a fine of eleven thousand pesos.

Doctrine

A judge is bound to decide cases within three months from the date of submission, as fixed by Article Eight, Section Fifteen of the Constitution. Under Administrative Circular Number Twenty-Eight, a case is deemed submitted for decision upon the filing of the last memorandum or upon the expiration of the period to file it, whichever is earlier. Failure to decide within the required period is undue delay in rendering a decision, a less serious charge under Section Nine, Rule One Hundred Forty of the Revised Rules of Court, penalized under Section Eleven, paragraph B by suspension or by a fine of more than ten thousand pesos but not exceeding twenty thousand pesos. Personal circumstances such as bereavement, an additional designation, or requests from litigants may mitigate but do not excuse the delay; the proper remedy is to ask for an extension or to go on leave.

Disposition

The Court found Judge Jules A. Mejia liable for undue delay in rendering a decision and imposed upon him a fine of eleven thousand pesos.

Remember This

Memorize the rule that a case is deemed submitted for decision upon the filing of the last memorandum or the expiration of the period to file it, whichever is earlier, and that delay beyond the three-month period is a less serious charge. Examiners use this case to test the classification and penalty for undue delay, and to test whether personal hardship mitigates but never excuses a judge's failure to decide on time.