MAGDADARO V. SANIEL JR.

AM No. RTJ-12-2331; December 10, 2012; Leonardo de-Castro, J.

SUMMARY: Magdadaros (complainant) car was involved in a car accident and
consequently, he had to buy a radiator from Bathala Marketing Industries, Inc. However, just
20-30 minutes after his radiator was replaced, the cars engine started to overheat again.
This time, complainant brought his car to Global Motors Cebu Distributors Corp. (Global
Motors) and had the radiator tank installed by BMII removed in the presence of a BMMI
representative. Global Motors issued a certification stating that the replacement radiator
tank that BMII installed in complainants car was not brand new but a reconditioned old
radiator tank. He then instituted a case against BMMI for breach of contract. Respondent
rendered a Decision on December 28, 2009 dismissing the complaint in Civil Case No. CEB27778 for lack of cause of action against the BMMI. Complainant filed a Notice to Appeal
which was only acted upon 6 months after filing. Frustrated with how the RTC was handling
his case, complainant filed the present administrative complaint against respondent on
October 17, 2011, alleging unreasonable delay by the respondent. Complainant also
asserted that respondent was ignorant of the law considering that the latter did not know
the respective liabilities and obligations of the parties in a comprehensive car insurance
contract. Complainant further claimed that respondent was partial or biased in favor of BMII.
Respondent, on the other hand, argued that the filing of the instant complaint was
premature and his office was undermanned, hence, the delay.
Issue:
WON the respondent should be held liable for the delay YES (see doctrine 2)
DOCTRINE: 1. An administrative complaint against a judge cannot be pursued
simultaneously with the judicial remedies accorded to parties aggrieved by his erroneous
order or judgment. Administrative remedies are neither alternative nor cumulative to judicial
review where such review is available to aggrieved parties and the same has not yet been
resolved with finality.
2. Section 15(1), Article VIII of the Constitution, mandates that cases or matters filed with
the lower courts must be decided or resolved within three months from the date they are
submitted for decision or resolution.
As a general principle, rules prescribing the time within which certain acts must be done, or
certain proceedings taken, are considered absolutely indispensable to the prevention of
needless delays and the orderly and speedy discharge of judicial business. By their very
nature, these rules are regarded as mandatory.