The Supreme Court in this case addressed the administrative liability of a judge for failing to promptly resolve a pending motion for a writ of preliminary injunction. While the judge was not found liable for gross ignorance of the law, the Court held that the delay in resolving the motion constituted undue delay, a less serious offense. This ruling underscores the judiciary’s commitment to the swift administration of justice, even amidst heavy caseloads, and serves as a reminder for judges to diligently manage their dockets and resolve pending matters within the prescribed periods.

Justice Delayed? Examining a Judge’s Duty to Expedite Preliminary Injunctions

This case arose from a complaint filed by Atty. Makilito B. Mahinay against Judge Ramon B. Daomilas, Jr. and Clerk of Court Atty. Rosadey E. Faelnar-Binongo, alleging gross inexcusable negligence and gross ignorance of the law. The central issue involved a protracted delay in resolving a prayer for a Temporary Restraining Order (TRO) and/or a Writ of Preliminary Injunction in SRC Case No. SRC-223-CEB, an intra-corporate dispute. Atty. Mahinay, representing the plaintiffs in the case, asserted that Judge Daomilas, Jr. violated the Interim Rules of Procedure for Intra-Corporate Controversies by failing to act on the prayer for injunctive relief for over two years, despite repeated motions for its resolution.

The complaint also targeted Clerk of Court Faelnar-Binongo, accusing her of colluding with Judge Daomilas, Jr. to delay the issuance of the writ by allowing the filing of a Motion for Reconsideration, which Atty. Mahinay considered a prohibited pleading. The Office of the Court Administrator (OCA) investigated the matter and found Judge Daomilas, Jr. guilty of undue delay in rendering an order, recommending a reprimand. The OCA, however, recommended the dismissal of the charges against Clerk of Court Faelnar-Binongo for lack of merit.

In its analysis, the Supreme Court underscored the importance of promptness in judicial proceedings. The Court emphasized that undue delay in the disposition of cases erodes public confidence in the judiciary and tarnishes its reputation. As a frontline official of the Judiciary, a trial judge is expected to act at all times with efficiency and probity, faithful to the law and maintaining professional competence.

The Court reiterated that not every error or mistake of a judge in the performance of official duties renders him liable. For liability to attach for ignorance of the law, the assailed action of the judge must not only be found erroneous but, most importantly, it must also be established that he was moved by bad faith, dishonesty, hatred, or some other like motive. In this instance, while the delay was evident, there was no clear indication of malicious intent on the part of the judge.

However, the Court distinguished between errors of judgment and inefficiency, finding Judge Daomilas, Jr. liable for the latter. While his actions regarding the counter-bond and motion for reconsideration were deemed judicial in nature and not subject to administrative scrutiny absent bad faith, the delay in resolving the application for a writ of preliminary injunction was deemed inexcusable. The Court highlighted that the November 6, 2015 Order granting the writ was issued beyond the ninety (90)-day period mandated by the Constitution, which requires judges to decide cases or resolve pending matters within three months from the date of the last pleading.

The Supreme Court referenced Section 15, paragraphs (1) and (2), Article 8 of the 1987 Constitution, which stipulates the time frame for resolution:

Section 15. (1) 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. (2) A case or matter shall be deemed submitted for decision or resolution upon the filing of the last pleading, brief, or memorandum required by the Rules of Court or by the court itself.

This constitutional provision emphasizes the judiciary’s commitment to resolving cases expeditiously. A judge’s failure to comply with these timelines, without justifiable reason, can lead to administrative sanctions. The Court further elaborated on the role of judges in maintaining court efficiency:

As a frontline official of the Judiciary, a trial judge should at all times act with efficiency and probity. He is duty-bound not only to be faithful to the law, but also to maintain professional competence. The pursuit of excellence ought always to be his guiding principle. Such dedication is the least that he can do to sustain the trust and confidence that the public have reposed in him and the institution he represents.

Despite finding Judge Daomilas, Jr. administratively liable, the Court considered mitigating circumstances, particularly his heavy caseload and the fact that he was managing two court stations with limited personnel. These factors contributed to a modification of the penalty, reducing it to a fine of P5,000.00. The Court also emphasized that this was the first time Judge Daomilas, Jr. had been found guilty of an administrative charge.

Regarding the charges against Clerk of Court Faelnar-Binongo, the Court concurred with the OCA’s recommendation for dismissal. The Court recognized that a clerk of court has no discretion to refuse the filing of pleadings, even if they appear contrary to law. Such a determination is a judicial function that rests solely with the judge. Moreover, Atty. Mahinay failed to provide substantial evidence to support his claim of collusion between the clerk of court and the judge.

The concept of substantial evidence is crucial in administrative proceedings. It is defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The absence of such evidence in this case led to the exoneration of Clerk of Court Faelnar-Binongo. In summary, the Court’s decision serves as a reminder of the importance of timely resolution of cases, while also acknowledging the challenges faced by judges and the need for evidence-based assessments in administrative proceedings.

This case underscores the balance between upholding judicial efficiency and recognizing the complexities of judicial work. While judges are expected to adhere to constitutional timelines for resolving cases, mitigating circumstances, such as heavy workloads and lack of resources, may be considered in determining the appropriate administrative penalty. This approach contrasts with a purely punitive one, aiming instead to promote improved judicial performance through a combination of accountability and understanding.

Ultimately, this decision highlights the judiciary’s commitment to both efficiency and fairness. While delays in resolving cases can undermine public trust, administrative sanctions must be proportionate to the offense and consider the realities of judicial practice. By balancing these competing concerns, the Supreme Court seeks to foster a judicial system that is both prompt and just.

The ruling demonstrates that the Philippine legal system acknowledges the impact of heavy workloads and resource constraints on judicial performance. While these factors do not excuse undue delay, they can serve as mitigating circumstances in administrative cases. This approach contrasts with a purely strict liability standard, reflecting a more nuanced understanding of the challenges faced by judges in the Philippines.

FAQs

What was the key issue in this case?	The key issue was whether Judge Daomilas, Jr. should be held administratively liable for the delay in resolving the motion for a writ of preliminary injunction.
What is the constitutional period for resolving cases?	The Constitution mandates that lower courts must resolve cases within three months from the date of the last pleading.
What mitigating circumstances did the Court consider?	The Court considered Judge Daomilas, Jr.’s heavy caseload and managing two court stations as mitigating circumstances.
What was the penalty imposed on Judge Daomilas, Jr.?	Judge Daomilas, Jr. was found guilty of Undue Delay in Rendering an Order and was fined P5,000.00.
Why was Clerk of Court Faelnar-Binongo exonerated?	Clerk of Court Faelnar-Binongo was exonerated because she had no discretion to refuse to file pleadings and there was no proof of collusion.
What is the standard of proof in administrative proceedings?	The standard of proof in administrative proceedings is substantial evidence.
What is ‘substantial evidence’?	Substantial evidence is relevant evidence that a reasonable mind might accept as adequate to support a conclusion.
What happens if a judge repeatedly delays cases?	A judge who repeatedly delays cases will face more severe penalties.
Does this case affect the timeline of deciding cases?	Yes, it is a constant reminder that judges must act promptly to avoid administrative liability.

This case reinforces the judiciary’s commitment to upholding the constitutional mandate of speedy disposition of cases. While acknowledging the challenges faced by judges, the Court’s decision underscores the importance of efficient court management and adherence to prescribed timelines. The ruling serves as a valuable reminder for judges to proactively manage their dockets and ensure timely resolution of pending matters, thereby promoting public trust and confidence in the judicial system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ATTY. MAKILITO B. MAHINAY v. HON. RAMON B. DAOMILAS, JR. AND ATTY. ROSADEY E. FAELNAR-BINONGO, G.R. No. 64514, June 18, 2018