A.M. No. MTJ-26-063 [Formerly JIB FPI No. 24-171-MTJ], June 23, 2026

HENRY GIBAGA PAMPLONA COMPLAINANT, VS. HON. ANTONIO GEOFFREY H. CANJA, PRESIDING JUDGE, MUNICIPAL TRIAL COURT [MTC], POLOMOLOK, SOUTH COTABATO, RESPONDENT.

Decisions / Signed Resolutions June 23, 2026 THIRD DIVISION INTING, J.:
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INTING, J.:

Before the Court is an Administrative Complaint[1] filed by Henry Gibaga Pamplona (Pamplona) against respondent Judge Antonio Geoffrey H. Canja (Judge Canja), presiding judge of Municipal Trial Court (MTC), Polomolok, South Cotabato, for gross ignorance of the law or procedure constituting violations of the Code of Judicial Conduct.

The Antecedents
The instant complaint stemmed from the Decision dated March 1, 2024, issued by Judge Canja in Civil Case No. 22-804, entitled Heirs of the Late Salvacion Gebaga Pamplona, et al. v. Sps. Camilo Cariño Diono, Jr. & Gloria Arenas Diono and Sps. Loreto Dalisay & Edith Detorio Dalisay for Quieting of Title, Declaration of Nullity of Sales, Cancellation of Land Titles and Tax Declarations.[2] The case pertained to the three-hectare portion of a parcel of land with a total area of eight hectares located in South Cotabato, and previously covered by Transfer Certificate of Title (TCT) No. T-33149.[3]

On March 1, 2024, Judge Canja rendered the Decision[4] in Civil Case No. 22-804, partially ruling in favor of the plaintiffs therein, the Pamplona heirs. In the said Decision, Judge Canja directed therein defendants Loreto and Edith Dalisay (collectively, Spouses Dalisay) to execute a deed of reconveyance over Lot No. 2536-B-2, covered by TCT No. 145-2019002694, in favor of the plaintiffs.[5]

On March 27, 2024, Spouses Dalisay filed an Ex-Parte Manifestation[6] wherein they stated that their counsel received the MTC Decision on March 14, 2024. They manifested their willingness to abide by the MTC’s ruling but asserted that the property to be reconveyed to the plaintiffs was not Lot No. 2536-B-2 covered by TCT No. 145-2019002694. Spouses Dalisay pointed out that the property sought by the heirs of Pamplona was the one occupied by them, i.e., Lot No.2536-B-3 covered by TCT No. 145-2019002695. On the same day, Judge Canja issued an Order[7] treating the Ex-Parte Manifestation as a Motion for Reconsideration and setting the matter for hearing on April 24, 2024.

On April 24, 2024, Judge Canja issued an Order[8] wherein he reset the scheduled hearing following the request of plaintiffs counsel to be furnished a copy of the Ex-Parte Manifestation, which said counsel allegedly did not receive.

Subsequently, the heirs of Pamplona, through counsel, filed their Vehement Opposition with Motion for the Issuance of a Writ of Execution.[9] They argued that: first, Judge Canja has no discretion to consider the Ex-Parte Manifestation as a motion;[10] and second, the Decision dated March 1, 2024, has already become final and executory because no motion for reconsideration was timely filed by Spouses Dalisay.

Judge Canja then issued an Order[11] dated May 14, 2024, denying the Motion for the Issuance of a Writ of Execution on the ground that the Decision dated March 1, 2024, has not attained finality. He explained that Spouses Dalisay’s Ex-Parte Manifestation was treated as a motion for reconsideration pursuant to the MTC’s inherent power under Rule 135, Section 5(g)[12] to amend and control the Decision dated March 1, 2024, so as to make it conformable to law and justice.

Thereafter, on May 16, 2024, Judge Canja issued an Amended Decision[13] dismissing Civil Case No. 22-804. He explained that the Decision dated March 1, 2024 was erroneous and that the Amended Decision conformed to the established facts and the Rules of Evidence. He ratiocinated that the statement made by Spouses Dalisay in their Judicial-Affidavit constituted an offer to compromise contemplated under Sections 27 and 28 of Rule 130 of the Rules of Evidence and was, therefore, inadmissible.[14] As such, he ordered the dismissal of Civil Case No. 22-804 for “failure of the plaintiff[s] to prove their case by preponderance of evidence.”[15]

Aggrieved, Pamplona filed the instant administrative complaint.

In his Complaint, Pamplona averred that Judge Canja exhibited gross ignorance of the law and incompetence when he treated the Ex-Parte Manifestation as a motion for reconsideration and amended the Decision dated March 1, 2024. Pamplona asserted that the Ex-Parte Manifestation was non-litigious and filed without notice to the adverse party; as such, it cannot be converted into or treated as a motion for reconsideration, which is litigious and requires notice and service to the adverse party.[16]

Pamplona added that Judge Canja became very angry and lost his temper when they submitted their Vehement Objection to the Ex-Parte Manifestation.[17] He further argued that Judge Canja reversed the final and executory Decision dated March 1, 2024, in Civil Case No. 22-804 ex-parte and without any proper hearing.[18]

In his Verified Comment,[19] Judge Canja argued that he rendered the Amended Decision in Civil Case No. 22-804 in accordance with the applicable laws and the evidence on record. He maintained that there was no impropriety in amending the Decision dated March 1, 2024. He explained that he treated the Ex-Parte Manifestation as a motion for reconsideration because (1) he realized that the Decision was erroneous; and (2) the Decision has not yet become final and executory, considering that the manifestation was filed within the 15-day reglementary period for Spouses Dalisay to appeal. He insisted that he treated the manifestation as a motion for reconsideration and amended the Decision to make it conformable to the established facts and the evidence presented.[20]

Judge Canja further denied that he lost his temper when he was informed that the Pamplona heirs intended to file a Vehement Opposition. He maintained that the transcripts of stenographic notes taken during the hearing, as well as the recordings of the video conferencing proceedings, do not support such allegation.

Report and Recommendation of the Judicial Integrity Office
In the Report and Recommendation[21] dated October 21, 2025, the Judicial Integrity Office (JIO) found Judge Canja administratively liable for gross ignorance of the law or procedure. It determined that Judge Canja erroneously treated the Ex-Parte Manifestation as a motion for reconsideration. It ratiocinated that treating the manifestation as a motion for reconsideration was contrary to the principle of due process, as it circumvented the procedural ru1es and deprived Pamplona of his opportunity to oppose and set his arguments, viz.:

IN VIEW OF THE FOREGOING, it is respectfully submitted for the consideration of the Honorable Court that:

1.)
The instant administrative matter be RE-DOCKETED;

2.)
Respondent Presiding Judge Antonio Geoffrey H. Canja, Municipal Trial Court, Polomolok, South Cotabato, be found GUILTY of Gross Ignorance of the Law or Procedure and FINED in the amount of PHP 50,000.00, payable within three months from receipt of the Decision or Resolution of the Supreme Court; and

3.)
Respondent Judge Canja be STERNLY WARNED that a repetition of the same or similar offense shall be dealt with more severely by the Supreme Court.[22]

Hence, the present case.

The Issue
The sole issue to be resolved in the case is whether Judge Canja is administratively liable for Gross Ignorance of the Law or Procedure when he motu proprio treated the Ex-Parte Manifestation as a motion for reconsideration, set Civil Case No. 22-804 for further hearing based thereon, and reversed the Decision dated March 1, 2024.

The Ruling of the Court
The Court finds the complaint unmeritorious.

Gross Ignorance of the Law or Procedure has been defined as “the disregard of the basic rules and settled jurisprudence”[23] or “the commission of a “gross or patent, deliberate or malicious’ error.”[24] The Court in Re: Anonymous Letter Complaining Against Pinto[25] described Gross Ignorance of the Law as follows:

We have previously held that when a law or a rule is basic, judges owe it to their office to simply apply the law. “Anything less is gross ignorance of the law.” There is gross ignorance of the law when an error committed by the judge was “gross or patent, deliberate or malicious.” It may also be committed when a judge ignores, contradicts or fails to apply settled law and jurisprudence because of bad faith, fraud, dishonesty or corruption. Gross ignorance of the law or incompetence cannot be excused by a claim of good faith.[26]

In the case at bench, the Court finds that Judge Canja did not act with gross ignorance of the law or procedure in Civil Case No. 22-804. Contrary to Pamplona’s assertions, Judge Canja acted in accordance with the law and the rules when he treated the Ex-Parte Manifestation as a motion for reconsideration, set the case for further hearing based thereon, and amended the Decision dated March 1, 2024.

In Festin v. Zubiri,[27] the Court distinguished the difference between a motion and a manifestation, to wit:

A manifestation is usually made merely for the information of the court, unless otherwise indicated. In a manifestation, the manifesting party makes a statement to inform the court, rather than to contest or argue. In contrast, a motion is an application for relief from the court other than by a pleading and must be accompanied by a notice of hearing and proof of service to the other party, unless the motion is not prejudicial to the rights of the adverse party. Settled is the rule that a motion without notice of hearing is pro forma or a mere scrap of paper; thus, the court has no reason to consider it and the clerk has no right to receive it. The reason for the rule is simple: to afford an opportunity for the other party to agree or object to the motion before the court resolves it. This is in keeping with the principle of due process.[28] (Emphasis supplied)

Simply stated, a manifestation is filed only to supply information to the court without seeking any reliefs. On the other hand, a motion “is an application for relief other than by a pleading.”[29] Whether a paper filed with the court is a manifestation or a motion is not just based on its caption; rather, the courts should carefully read the body of the document and the allegations therein.[30]

In the case, Judge Canja promulgated the Decision dated March 1, 2024, which directed Spouses Dalisay to reconvey to the Pamplona heirs Lot No. 2536-B-2 covered by TCT No. 145-2019002694.[31] Subsequently, Spouses Dalisay filed the Ex-Parte Manifestation, stating that the Decision should reflect that the property sought by the Pamplona heirs was actually Lot No. 2536-B-3 covered by TCT No. 145-2019002695.

Evidently, the Ex-Parte Manifestation, though captioned as such, is in truth a motion. Therein, Spouses Dalisay not only supplied information to the MTC but also argued that the trial court erred in designating the property to be conveyed. Additionally, the manifestation sought a substantial amendment of the Decision—a change in the identity of the land to be conveyed to the Pamplona heirs—and contained a prayer for equitable reliefs, viz.:

Hence, defendant Loreto Dalisay earnestly and humbly prays that the Honorable Court shall correctly reflect in the issued Decision the proper and accurate lot to be conveyed to the plaintiffs, the heirs of Salvacion Pamplona which is really Lot No. 2536-B-3 and covered by TCT No. 145-2019002695 comprising a total land area of TEN THOUSAND (10,000) Square meters and not Lot No. 2536-B-2 covered by TCT [No.] 145-2019002694 which (sic) a total land area of FIFTEEN THOUSAND (15,000) Square meters. Attached are photocopies of the titles of said real properties for the guidance of the Honorable Court; and

. . . .

WHEREFORE, premises considered, it is respectfully and earnestly prayed that this manifestation be noted and that the subject lot to be conveyed to the heirs of the late Salvacion Pamplona which is indeed Lot No. 2536-B-3 and covered by TCT No. 145-2019002695 be correctly stated in the Decision rendered by the Honorable Court.

FURTHER, the defendant Loreto Dalisay respectfully prays for such other reliefs and remedies as may be deemed just and equitable in the premises.

RESPECTFULLY SUBMITTED.[32] (Italics supplied)

It is equally important to point out that in actions involving the recovery of title to land, the identity of the property in issue, including its location, area, and boundaries, is a material matter.[33] The change in even a single digit in the designation of the lot and title numbers could materially alter the results of the case.[34] Judges must therefore exercise caution in issuing reconveyance orders lest they disturb the integrity of the Torrens System, which is in place precisely to quiet title to land and avert issues on the legality of a party’s title.[35]

Here, the Ex-Parte Manifestation sought a material modification of the MTC Decision with regard to the designation of the property for reconveyance. Judge Canja could not simply rely on the allegations in the Ex-Parte Manifestation and amend the Decision outright. His act of setting the matter for hearing to verify the correctness of the property’s identity reflects prudence and due regard for the stability of land registration. Rather than demonstrate ignorance of the law, his actions are consistent with the standard of competence that is expected of magistrates under Canon VI, Section 1[36] of A.M. No. 25-04-04-SC or the 2025 Code of Judicial Conduct and Accountability.

Pamplona nonetheless insists that Judge Canja acted with gross ignorance of the law or rules because the Ex-Parte Manifestation is a non-litigious submission that is not heard nor served on the adverse party; on the other hand, a motion for reconsideration is litigious and must be served on the adverse party. Supposedly, Judge Canja acted upon the manifestation and issued the Amended Decision ex-parte or without proper notice and hearing.

Pamplona’s arguments lack merit.
 
Contrary to Pamplona’s assertions, the records show that the Ex-Parte Manifestation, despite its caption, was served on Pamplona’s counsel through registered and electronic mail.[37] The Ex-Parte Manifestation even contained an explanation on such modes of service.[38]

Furthermore, Judge Canja set the Ex-Parte Manifestation for hearing thrice: first, on April 24, 2024;[39] second, on May 8, 2024;[40] and third, on June 19, 2024.[41] Importantly, during the hearing held on April 24, 2024, where counsel for both parties were present, Judge Canja categorically expressed that Spouses Dalisay’s counsel must furnish a copy of the Ex-Parte Manifestation to the Pamplona heirs.[42]

Significantly, in the Vehement Opposition, plaintiffs counsel copied a portion of the Ex-Parte Manifestation verbatim.[43] This goes to show that plaintiffs counsel was duly notified of the Ex-Parte Manifestation. Even more, Judge Canja took cognizance of the Vehement Opposition and acted upon it on May 14, 2024,[44] before he issued the Amended Decision on May 16, 2024.[45]

Evidently, the plaintiffs were given the opportunity to argue their cause not only during the scheduled hearings but also through the filing of the Vehement Opposition, which was considered and resolved by Judge Canja before he rendered the Amended Decision. Pamplona is therefore mistaken in his assertion that Judge Canja acted upon the Ex-Parte Manifestation and amended the Decision without prior notice and hearing.

At any rate, even without a motion for reconsideration, Judge Canja could motu proprio set the case for further hearing and amend the Decision in Civil Case No. 22-804.

Under Rule 135, Section 5(g)[46] of the Rules of Court, courts possess the inherent power to “amend and control its process and orders so as to make them conformable to law and justice.” This inherent power authorizes judges to, either upon motion of a party or motu proprio, amend, modify, or reverse a decision, order, or judgment within the reglementary period to make them conformable to law and to avoid injustice.[47] The power “includes the right of the court to reverse itself, especially when in its honest opinion it has committed an error or mistake in judgment, and that to adhere to its decision will cause injustice to a party litigant.”[48]

Thus, in several cases, the Court held that pursuant to Rule 135, Section 5 (g) of the Rules of Court, judges may motu proprio recall an entry of judgment of a court resolution that has not yet attained finality;[49] order the reopening of trial;[50] amend an order directing the issuance of a writ of possession;[51] and even recall a final decision when the judge receives information that seriously affects the court’s subject matter jurisdiction and render the decision void.[52]

To restate, under Rule 135, Section 5 (g) of the Rules of Court, a court may, upon motion or on its own, amend, modify, revise, or set aside its own decisions, orders, and resolutions provided that: 1) the court, in its honest belief, finds that there is an error in the judgment; 2) the amendment is made within the reglementary period prescribed by the law or rules or even beyond it, provided that the action is grounded on lack of subject matter jurisdiction; and 3) the amendment is undertaken to make the judgment conformable with the law and the rules, or to prevent a miscarriage of justice.

In the present case, Judge Canja correctly argues that in setting Civil Case No. 22-804 for further hearing, he simply exercised the MTC’s inherent power to amend or reverse its judgment to make it conformable with the law and the rules.

As explained by Judge Canja in his Verified Comment, the statements in the Ex-Parte Manifestation made him believe that he committed an error in the Decision in Civil Case No. 22-804.[53] His assertions are supported by the records of the hearing held on April 24, 2024, where he clearly expressed that the new information supplied in the Ex-Parte Manifestation may warrant the amendment of the Decision, viz.:

COURT:

Okay, sit down. Make it of record that Atty. Rex Batay-an was allowed to appear remotely without him filing a written motion to appear remotely due to exigency…. This Court set the hearing of your ah what’s that, manifestation?

ATTY. COSEP:

Yes, Your Honor.

COURT:

Because if indeed, it is true I hat the lot that is sought by the plaintiff to be qui[e]ted because they, are in possession thereof, and it is already titled in their name according to you but, you cannot just transfer to them because they are ah you wanted them to ah your client wanted them to come to you ah that matter should be ah the decision in this case should be amended, right?

ATTY. COSEP:

Yes, Your Honor.

COURT:

So, there is a need to amend the Decision. That’s why I also invited Atty. Rex Batay-an, the plaintiff’s counsel if they are am[e]nable to the amendment.[54]

. . . .

COURT:

…So, the Decision it states, it is 262536B-2, so there’s a difference, right? It’s only the lot number, okay? And that lot 2536-B-2. In other words, [Spouses Dalisay] are willing to reconvey, they stated here in the manifestation that they been waiting for you for a long time already so that, the particular one (1) hectare could be transferred in your name already because the property has been in your possession since – I don’t know, since maybe it was sold. The problem is, here I will tell you…. [Your lawyer] did not say that that property, that one (1) hectare property you’re possessing is the one that should be reconveyed to you. He did not allege that in this…it’s only later that this Court found out that this particular lot that should be reconveyed is that one (1) hectare because you know why I decided that way….[55]

Furthermore, the records show that Spouses Dalisay’s counsel received the Decision on March 14, 2024.[56] 13 days later, or on March 27, 2024, Spouses Dalisay filed the Ex-Parte Manifestation. On the same day, Judge Canja issued the Order of even date, wherein he treated the Ex-Parte Manifestation as a motion for reconsideration and scheduled it for hearing on April 24, 2024.

Clearly, when Judge Canja issued the Order dated March 27, 2024, only 13 days had lapsed from the date when Spouses Dalisay were notified of the Decision dated March 1, 2024. Evidently, he opted to set the case for further hearing with a view to modifying the Decision within the 15-day reglementary period to appeal under Rule III, Part C, Section 1[57] of the Rules on Expedited Procedures and Rule 40, Section 2[58] of the Rules of Court. He therefore, properly and timely exercised the inherent power of the MTC under Rule 135, Section 5(g).

Undeterred, Pamplona contends that the Ex-Parte Manifestation referred only to the amendment of the designation of the property to be reconveyed to the plaintiffs in Civil Case No. 22-804. He thus insists that Judge Canja committed gross ignorance of the law when he reversed the Decision in its entirety and did not limit his action to the matters set forth in the Ex-Parte Manifestation.[59]

The Court is not convinced by Pamplona’s arguments.

The constitutional mandate of the courts is to decide a case based on the evidence and the applicable laws and jurisprudence.[60] The discretion of judges to resolve a case is broad: as long as their conclusions are legally tenable and supported by law and the facts on record, they may adopt or refuse the parties’ arguments.[61]

Accordingly, Judge Canja is not bound by either parties’ arguments or contentions in deciding Civil Case No. 22-804. Rather, his duty is to decide it based on the applicable laws and the evidence presented. The mere fact that the Amended Decision went beyond the allegations in the Ex-Parte Manifestation is therefore insufficient to conclude that he acted with gross ignorance of the law or procedure.

To the mind of the Court, the present administrative complaint already delves into the merits of the Amended Decision in Civil Case No. 22-804 and impute errors to Judge Canja’s exercise of his judicial functions. However, it is beyond cavil that “errors, if any, committed by a judge in the exercise of his adjudicative functions cannot be corrected through administrative proceedings, but should instead be assailed through available judicial remedies.”[62] 
 
Stated otherwise, the filing of an administrative complaint is improper where adequate judicial remedies remain available, such as a motion for reconsideration, an appeal, or a petition for certiorari.[63] Resort to and exhaustion of judicial remedies are pre-requisites for taking disciplinary measures against the judges concerned.[64] As such, in Governor Tallado v. Judge Racoma,[65] the Court laid down the guidelines for evaluating administrative disciplinary cases against justices, judges, and court personnel, to wit:

Thus, to safeguard against the abuse of the administrative disciplinary mechanism against justices, judges, and court personnel, the [Judicial Integrity Board (JIB)] must be guided by the following rules in evaluating administrative disciplinary cases:   
 

(1)
If a judicial remedy is still available to the complainant, the administrative complaint shall be dismissed outright, without prejudice to re-filing should the complainant succeed in a judicial action in proving that the public respondent’s assailed act or omission was indeed wrong and ill motivated.

(2)
If the administrative case is meant to harass, threaten or merely vex the public respondent, the same shall be dismissed. In determining this, the following factors may be considered:

(a)
the existence of other cases file against the public respondent by the same complainant or related complainants;

(b)
the position and influence of the complainant, particularly in the locality where the public respondent is stationed;

(c)
the number of times that the public respondent has been charged administratively and the corresponding dispositions in these cases;

(d)
any decisions or judicial actions previously rendered by the public respondent for or against the complainant;

(e)
the propensity of the complainant for filing administrative cases against members and personnel of the Judiciary; and

(f)
any other factor indicative of improper pressure or influence.[66]

Considering that the acts complained of pertain to Judge Canja’s adjudicative functions, Pamplona should have first exhausted all available judicial remedies before resorting to administrative disciplinary proceedings. Nothing in the Complaint demonstrates that Pamplona and his co-heirs have met the pre-requisites to the filing of the present Complaint by exhausting all the judicial remedies that are available to them against the Amended Decision in Civil Case No. 22-804. The dismissal of the complaint is thus warranted under the circumstances.

Moreover, in several cases,[67] the Court repeatedly held that “[i]n the absence of fraud, dishonesty or corruption, the acts of a judge in his judicial capacity are not subject to disciplinary action.”[68] There is nothing in the records showing that Judge Canja acted with ill motives or bad faith in treating the Ex-Parte Manifestation as a motion for reconsideration and amending the Decision dated March 1, 2024.

Lastly, with respect to the allegation of improper conduct against Judge Canja for allegedly losing his temper, the Court reiterates that complainants must establish their claims by substantial evidence.[69] In the case, Pamplona’s bare allegation that Judge Canja lost his temper is unsubstantiated, as the records do not show Judge Canja, upon being informed of the intent to file a Vehement Opposition, lost his temper and acted with hostility toward Pamplona’s counsel.

All told, the Court finds that the Administrative Complaint filed against Judge Canja should be dismissed for lack of merit. The records do not support Pamplona’s contention that Judge Canja acted with gross ignorance of the law or the rules in Civil Case No. 22-804 when he considered the Ex-Parte Manifestation as a motion for reconsideration and amended the Decision dated March 1, 2024.

ACCORDINGLY, the Administrative Complaint against respondent Hon. Antonio Geoffrey H. Canja, Presiding Judge of Municipal Trial Court, Polomolok, South Cotabato is DISMISSED for lack of merit. Consequently, the case is deemed CLOSED and TERMINATED.

SO ORDERED.

Caguioa (Acting C.J.), Gaerlan, Dimaampao, and Singh, JJ., concur.


[1] Rollo, pp. 1-13.
 
[2] Id. at 2 and 23.

[3] Id. at 23.

[4] Id. at 23-28.

[5] Id. at 28.

[6] Id. at 3-37. See Ex-Parte Manifestation dated March 27, 2024.

[7] Id. at 32.

[8] Id. at 33.

[9] Id. at 38-45.

[10] Id. at 38-39.

[11] Id. at 63-64.

[12] Section 5. Inherent powers of court. — Every court shall have power:

. . . .

(g) To amend and control its process and orders so as to make them conformable to law and justice.

[13] Rollo, pp. 56-62.

[14] Id. at 61.

[15] Id. at 62.

[16] Id. at 4.

[17] Id. at 4-7.

[18] Id. at 2.

[19] Id. at 71-75. See Verified Comment/Compliance to Show Cause Order.

[20] Id. at 72.

[21] Id. at 101-107. Signed by Eduardo C. Tolentino, Officer-In-Charge, Judicial Integrity Office.

[22] Id. at 106-107.

[23] Mañalac v. Gellada, 841 Phil. 521, 530 (2018) [Per J. Del Castillo, First Division], citing Recto v. Trocino, 820 Phil. 430, 444 (2017) [Per Curiam, En Banc].

[24] Sismaet v. Cruzabra, 881 Phil. 577, 584 (2020) [Per J. Gaerlan, Third Division] citing Alfelor v. Diaz, 813 Phil. 544, 552-553 (2017)[Per J. Caguioa, En Banc].

[25] 696 Phil. 21 (2012) [Per Curiam, En Banc].

[26] Id. at 28.

[27] 811 Phil. 1 (2017) [Per J. Perlas-Bernabe, First Division].

[28] Id. at 9-10.

[29] Rules of Court, Rule 15, sec. 1.

[30] Sps. Munsalud v. National Housing Authority, 595 Phi. 750, 765 (2008) [Per J. R.T. Reyes, Third Division].

[31] Rollo, p. 28. 

[32] Id. at 30.

[33] See Beo v. Court of Appeals, 277 Phil. 658, 665 (1991) [Per J. Gancayco, First Division]. See also Del Rosario v. Republic, 432 Phil. 824, 836 (2002) [Per J. Mendoza, Second Division].

[34] See Castañeto v. Spouses Adame, 940 Phil. 130 (2023) [Per J. Inting, Third Division], and Republic v. Spouses Bercede, 932 Phil. 851 (2023) [Per J. Kho Jr., En Banc].

[35] See Encinares v. Achero, 613 Phil. 391, 407 (2009) [Per J. Nachura, Third Division].

[36] CANON VI

Competence and Diligence

Competence and diligence encompass a judge’s knowledge, skills, values, and personal qualities necessary to efficiently and effectively perform their noble role of dispensing justice fairly and objectively.

Competence is the ability to perform adjudicative and administrative functions efficiently and effectively.

Diligence is the consistent and earnest effort of a judge to discharge their adjudicative and administrative functions in a manner that prevents delay, oppression, and injustice.

SECTION 1. Requirement of Highest Professional Competence and Diligence. — A judge shall be faithful to one’s official duties and maintain the highest standard of professional competence and diligence.

[37] Rollo, pp. 34 and 99.

[38] Id. at 31.

[39] Id. at 85-88, TSN dated April 24, 2024.

[40] Id. at 33.

[41] Id. at 55. However, the June 19, 2024 hearing was cancelled in light of the Vehement Opposition, as stated in the Order dated May 14, 2024 (id. at 63-64).

[42] Id. at 87-88, TSN dated April 24, 2024.

[43] Id. at 48.

[44] Id. at 63-64.

[45] Id. at 62.

[46] SEC. 5. Inherent powers of courts. – Every court shall have power:

. . . .
 
(g) to amend and control its process and orders so as to make them conformable to law and justice.

[47] Bachrach Motor Co., Inc. v. Kane, 61 Phil. 504, 510 (1935) [Per J. Diaz, En Banc].

[48] Republic v. Hon. Gingoyon, 514 Phjl. 657, 713 (2005) [Per J. Tinga, En Banc].

[49] Realty Sales Enterprises, Inc. v. Intermediate Appellate Court, 254 Phil. 719 (1989) [Per Curiam, En Banc].

[50] Id. at 722.

[51] Gingoyon, supra, at 713.

[52] See Rivera v. Catalo, 764 Phii. 257, 264 (2015) [Per J. Mendoza, Second Division].

[53] Rollo, p. 101.

[54] Rollo, pp. 77-78, TSN, Atty. Rex Batay-an, April 24, 2024.

[55] Id. at 80-81.

[56] Id. at 29.

[57] Section 1. Ordinary appeal. – Any judgment, final order, or final resolution in a Summary Procedure case may be appealed to the appropriate Regional Trial Court exercising jurisdiction over the territory under Rule 40 for civil cases and Rule 122 for criminal cases, of the Rules of Court. The appeal shall be taken by filing a notice of appeal, together with proof of payment of the appeal fees, with the court that rendered the judgment, order or resolution appealed from, within fifteen (15) calendar days from receipt of the same.

[58] Section 2. When to appeal. — An appeal may be taken within fifteen (15) days after notice to the appellant of the judgment or final order appealed from. Where a record on appeal is required, the appellant shall file a notice of appeal and a record on appeal with in thirty (30) days after notice of the judgment or final order.

[59] Rollo, p. 5.

[60] Billoso v. People, 933 Phil. 332, 340 (2023) [Per J. J. Lopez, Second Division]; Secretary of the Department of Environment and Natural Resources v. Yap, 589 Phil. 156, 199 (2008) [Per J. R.T. Reyes, En Banc].

[61] See Sicam v. Jorge, 556 Phil. 278, 286 (2007) [Per J. Austria-Martinez, Third Division] and Nuez v. National Labor Relations Commission, 309 Phil. 476, 484 (1994) [Per J. Bellosillo, First Division].

[62] Valmores-Salinas v. Bitas, 706 Phil. 472, 476 (2013) [Per J. Peralta, Third Division].

[63] Governor Tallado v. Judge Racoma, 929 Phil. 40, 49 (2022) [Per J. Singh, En Banc], Valmores-Salinas v. Bitas, id. at 476, Bello III v. Diaz, 459 Phil. 214, 221 (2003) [Per J. Austria-Martinez, Second Division].

[64] Baysa v. Santos, 917 Phil. 372, 379 (2021) [Per J. Lazaro-Javier, First Division].

[65] Governor Tallado v. Judge Racoma, supra note 64.

[66] Id. at pp. 55-56.

[67] Valmores-Salinas v. Bitas, supra note 63 at 477; Salvador v. Limsiaco, Jr., 519 Phil. 683, 687 (2006) [Per J. Callejo, Sr., First Division].

[68] Rollo, pp. 35-37.

[69] Re: Letter of Lucena Ofendoreyes, 810 Phil. 369, 373 (2017) [Per J. Perlas-Bernabe, En Banc].