Domdon v. Lopez
REITERATIONFacts
The Antecedents: Complainants, students and members of the editorial board of AMA Computer College's publication Dataline, published a spoof edition titled Amable Tonite. Following an investigation by the school's Disciplinary Tribunal, which recommended their expulsion, the complainants filed a complaint for damages and injunctive relief. They alleged that their expulsion was despotic, oppressive, and violated their constitutional rights to due process and free speech, as well as the Campus Journalism Act of 1991. The school and its Dean of Student Affairs opposed the complaint, asserting that the spoof edition contained slanderous and derogatory articles, that the complainants had violated school policies and laws, and that they had been afforded due process. Procedural History: The complainants filed a civil case for damages and a preliminary mandatory injunction against AMA Computer College and its Dean of Student Affairs in the Regional Trial Court of Quezon City, assigned to respondent Judge Percival Mandap Lopez. The respondent judge initially received opposition and a reply from the defendants, followed by a rejoinder. Despite the complainants' urgent pleas to resolve the injunction request before the enrollment period, the judge dismissed the entire case on June 14, 1997, finding the expulsion to be for cause and after due investigation. The complainants moved for reconsideration, arguing that a trial was necessary and that the dismissal was premature. They also sought the judge's disqualification. The judge denied both motions on September 26, 1997. The Office of the Court Administrator (OCA) later found the judge guilty of undue delay and gross ignorance of the law. The Petition: This administrative complaint was filed against Judge Lopez for undue delay and gross ignorance of the law. The complainants alleged that the judge deliberately delayed the resolution of their motion for a preliminary mandatory injunction, rendering the issue moot by failing to act before the enrollment period. They further charged him with gross ignorance of the law for dismissing their case without a proper trial, based solely on pleadings and unverified defenses, and without affording them an opportunity to present evidence. Additionally, they claimed the judge antedated a resolution denying their motion for reconsideration and motion to inhibit, which they received nearly five months after its supposed issuance, indicating a pattern of misconduct similar to a previous reprimand he received.
Issue(s)
Whether the respondent judge was guilty of undue delay in resolving the application for a writ of preliminary mandatory injunction. Whether the respondent judge committed gross ignorance of the law in dismissing the case without trial. Whether the respondent judge was guilty of delaying the service of his resolution denying the motion for reconsideration and motion to inhibit.
Ruling
The Supreme Court found the respondent judge guilty of gross ignorance of the law, undue delay in the resolution of the writ of preliminary mandatory injunction, and failure to heed a prior warning. He was ordered to pay a fine of P5,000.00 with a warning of more severe sanctions for repetition of similar offenses.
Ratio Decidendi
On the issue of undue delay in resolving the injunction: The Court agreed with the OCA that the respondent judge was guilty of undue delay. While the Rules of Court do not prescribe a specific period for resolving injunctions, judges are guided by the exigencies of the situation. The complainants sought the writ to be readmitted and to enroll for the first trimester of the school year 1997-1998. The judge's resolution on June 14, 1997, after the enrollment period had likely passed, rendered the injunction moot. The judge's excuse that the delay was due to the defendants' late filing of their rejoinder was unmeritorious, as he should have considered the rejoinder waived and resolved the injunction promptly. His procrastination opened him to suspicion of favoring the defendants. Canon 3, Rule 3.05 of the Code of Judicial Conduct enjoins judges to dispose of court business promptly. On the issue of gross ignorance of the law in dismissing the case without trial: The Court found that the respondent judge committed gross ignorance of the law by dismissing the case on the merits without conducting a trial. The defendants' rejoinder, which the judge treated as a motion to dismiss for lack of cause of action, did not qualify as such under Rule 16 or Rule 33 of the Rules of Civil Procedure. A motion to dismiss under Rule 16 is based on preliminary objections, while a demurrer to evidence under Rule 33 is filed after the plaintiff has presented evidence. The rejoinder raised factual matters and affirmative defenses, not a failure of the complaint to state a cause of action. The judge's resolution essentially decided the case on the merits by accepting the defendants' unproven affirmative defenses as facts, without allowing the complainants to present their evidence. Factual issues, such as whether the expulsion was solely based on the spoof publication and whether due process was observed, required a trial. On the issue of delaying the service of the resolution: The Court noted that the respondent judge did not deny the complainants' allegation that the resolution denying their motion for reconsideration and inhibition was received almost five months after its supposed issuance. This delay in service, coupled with a previous reprimand for a similar offense, indicated a pattern of misconduct. Judges are responsible for managing their courts to ensure prompt disposition of business, and the delay in service was solely attributable to the respondent judge.
Main Doctrine
A judge who unduly delays the resolution of a motion for preliminary injunction, thereby rendering the issue moot, and dismisses a case without trial on the basis of unproven affirmative defenses, commits gross ignorance of the law and undue delay, warranting a fine.