Phividec Industrial Authority v.
Capitol Steel Corporation, G.R.
No. 155692, 23 October 2003
The people involved in this case are:
1. Imelda Y. Maderada - Complainant and clerk of court who filed the complaint
against Judge Mediodea.
2. Judge Ernesto H. Mediodea - Respondent judge of the 12th Municipal Circuit
Trial Court accused of gross ignorance of the law and inefficiency.
3. Judge Erlinda Tersol - The judge who initially presided over the case but
inhibited herself due to Maderada's position.
4. Executive Judge Tito Gustilo - Designated Judge who assigned Judge
Mediodea to hear the case.
5. Defendants in the forcible entry action - The parties against whom Maderada
filed her complaint.
These individuals play significant roles in the proceedings and the ethical
concerns raised in the case.
Facts:
The case involves a complaint filed by Imelda Y. Maderada against Judge
Ernesto H. Mediodea of the 12th Municipal Circuit Trial Court (MCTC) of
Cabatuan and Maasin, Iloilo.
Maderada, who was the clerk of court in the same sala, filed an action for
forcible entry with a prayer for preliminary injunction, temporary restraining
order (TRO), and damages against certain defendants.
Judge Mediodea was designated to hear the case after the original judge
inhibited herself. However, the case remained unresolved for four months,
Phividec Industrial Authority v. Capitol Steel Corporation, G.R. No. 155692, 23 October 2003 1
prompting Maderada to file a complaint against Judge Mediodea for gross
ignorance of the law amounting to grave misconduct.
Issue:
The main issues raised in this case are: (1) Is Judge Mediodea guilty of gross
inefficiency in deciding cases? and (2) Is Imelda Y. Maderada liable for appearing
as counsel on behalf of her co-plaintiff without court authority?
Ruling:
The Supreme Court ruled that (1) Judge Mediodea is found guilty of gross
inefficiency in failing to observe the reglementary periods in deciding cases and is
fined P10,000 with a stern warning that a repetition of the same or of a similar act
in the future shall be dealt with more severely. (2) Imelda Y. Maderada is
reprimanded for appearing as counsel on behalf of a co-plaintiff without court
authority and is warned that a future similar act shall be sanctioned more severely.
What is the primary allegation against Judge Ernesto H. Mediodea in the
complaint filed by Imelda Y. Maderada?
The primary allegation is 'gross ignorance of the law amounting to grave
misconduct' due to his failure to apply the Revised Rule on Summary Procedure in
a forcible entry action.
How long did the preliminary injunction remain unresolved according to the
Office of the Court Administrator (OCA)?
The preliminary injunction remained unresolved for four months, whereas it should
have been resolved within 30 days.
What principle did the court emphasize regarding the resolution of cases?
Phividec Industrial Authority v. Capitol Steel Corporation, G.R. No. 155692, 23 October 2003 2
The court emphasized the importance of prompt case resolution to maintain
public confidence in the judiciary.
What were the reasons given by Judge Mediodea for the delays in the
proceedings?
Judge Mediodea claimed that the delays were due to Maderada's failure to
present necessary evidence and to exhaust available remedies.
What legal principle is reinforced regarding judicial employees engaging in legal
representation?
Judicial employees must uphold the integrity of the judicial system and seek
proper authorization when engaging in legal representation.
Phividec Industrial Authority v. Capitol Steel Corporation, G.R. No. 155692, 23 October 2003 3