RTC judge fined for undue delay in resolving GMA Network complaint v Mo Twister, ABC5

The Supreme Court (SC) fined Quezon City Regional Trial Court (RTC) Judge Santiago Arenas in the amount of P5,000 and reminded him to be more efficient and prompt in the performance of his duties.

This followed a complaint-affidavit filed with the Highest Court by GMA Network on July 29, 2011 that charged Arenas with gross inefficiency and undue delay in resolving the civil case docketed as Q-10-67164 and entitled “GMA Network, Inc. vs. Mohan Gumatay a.k.a. “Mo Twister” and Associated Broadcast Company (ABC5).”

GMA filed the complaint against Gumatay for breach of contract on May 25, 2010 which was raffled to Quezon City RTC Branch 217. GMA sought the issuance of a Temporary Restraining Order (TRO) and/or writ of preliminary injunction to stop Gumatay’s appearance on ABC5.

Gumatay had signed an exclusive contract with GMA on May 4, 2009, which granted GMA the exclusive and irrevocable option to renew the contract. The latter exercised said option and denied Gumatay’s request to be released from his contact. Nonetheless, Gumatay proceeded to accept the offer of ABC5 to appear on its shows.

Arenas denied GMA’s application for the issuance of a TRO and set a hearing for a writ of preliminary injunction in an Order dated December 10, 2010.

According to GMA, Arenas discarded GMA’s position that Gumatay had a live and subsisting contract with GMA. By reason of exercise of its exclusive and irrevocable option to renew Gumatay’s Talent Agreement, GMA was entitled to the relief of a TRO and/or preliminary injunction.

In response to the December 10, 2010 Order of Arenas, GMA filed a Motion for Voluntary Inhibition on January 24, 2011 against the presiding judge, arguing that Arenas already pre-judged the case on the merits.

Moreover, GMA’s complaint asserted that Arenas “has been deliberately sitting on its Motion for Voluntary Inhibition for more than four months since the filing of ABC5’s Rejoinder dated March 16, 2011.” GMA also said that Arenas’ gross inefficiency and deliberate inaction caused GMA prejudice and irreparable injury.

The SC adopted and approved the findings and recommendations of the Office of the Court Administrator (OCA) contained in the Report dated January 25, 2012 signed by Court Administrator Jose Midas Marquez and OCA Chief of Office Wilhelmina Geronga. In the said report, it was found that Arenas incurred unreasonable delay in resolving the Motion for Voluntary Inhibition. The said motion should have been resolved within 90 days from the date it was deemed submitted for resolution on April 26, 2011 pursuant to Article VIII, Section 15 of the Constitution. Arenas’ undue delay in resolving a mere motion for inhibition violated the said law.

Supreme Court Circular No. 13 dated July 1, 1987 instructs judges to observe the periods prescribed by the Constitution in adjudicating and resolving all cases or matters submitted to the court.

According to the OCA, “the public’s faith and confidence in the judicial system depends largely on the judicious and prompt disposition of cases…Failure to decide on a case or resolve a motion within the prescribed period constitutes gross inefficiency and warrants the imposition of administrative sanction against the erring judge.”

SC also warned Arenas that repetition of undue delay shall be dealt with more severely.