Mahinay v. Daomilas
REITERATIONFacts
The Antecedents: Atty. Makilito B. Mahinay filed a complaint against Judge Ramon B. Daomilas, Jr. and Clerk of Court V Atty. Rosadey E. Faelnar-Binongo for gross inexcusable negligence and gross ignorance of the law. The complaint stemmed from the alleged delay in the resolution of a prayer for a Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction in SRC Case No. SRC-223-CEB, a case where Atty. Mahinay was counsel for the plaintiffs. The complaint for Judicial Declaration of Nullity of Shareholdings was filed on December 19, 2012, and the prayer for injunctive relief was submitted for resolution in March 2013. Procedural History: Atty. Mahinay alleged that Judge Daomilas, Jr. failed to act on the prayer for TRO and/or preliminary injunction for over two years, despite repeated motions. On November 3, 2015, Atty. Mahinay wrote the Office of the Court Administrator (OCA) for assistance. On November 6, 2015, Judge Daomilas, Jr. issued an Order granting the preliminary injunction, conditioned upon the plaintiffs posting a bond of P10,874,992.00. The defendants sought reconsideration and prayed to post a counter-bond, which was set for hearing the next day. Defendants later filed a Manifestation regarding alleged misrepresentations by plaintiffs to banks. On November 16, 2015, plaintiffs posted the surety bond. On the same day, Judge Daomilas, Jr. issued an Order directing plaintiffs to comment on the defendants' Motion for Reconsideration and Urgent Prayer to Post a Counter-bond. On January 18, 2016, Atty. Mahinay again wrote the OCA, reporting the delay. Before the OCA responded, Judge Daomilas, Jr. issued an Order dated January 20, 2016, denying the Motion for Reconsideration but granting the Motion to File Counter-bond. Plaintiffs filed a Motion to Recall the January 20, 2016 Order, but later withdrew it to file a petition for mandamus and certiorari before the Court of Appeals. Atty. Mahinay also accused Clerk of Court Faelnar-Binongo of collusion in delaying the injunction by allowing the filing of a prohibited motion for reconsideration. The OCA directed respondents to file their Comments. Judge Daomilas, Jr. denied delaying the resolution, citing heavy caseload, concurrent assignments, and limited staff. He asserted that allowing a counter-bond is permitted under the Rules of Court and the Interim Rules, and that the January 20, 2016 Order was to address confusion caused by plaintiffs' alleged misrepresentations. He also claimed good cause for the early hearing of the motion. Clerk of Court Faelnar-Binongo denied collusion, stating her duty to receive pleadings is ministerial and that determining if a pleading is prohibited is a judicial function. She also cited the rule allowing shorter notice periods for good cause and alleged Atty. Mahinay's propensity for filing baseless administrative cases. Atty. Mahinay reiterated his allegations in a Reply, emphasizing the delay and accusing the judge of not acting promptly on other motions. The Petition: The OCA recommended that Judge Daomilas, Jr. be found guilty of Undue Delay in Rendering an Order, noting the delay beyond the 90-day constitutional period and the lack of a motion for extension. However, it recommended a reduced penalty of reprimand due to his heavy caseload. The OCA recommended dismissal of charges against Clerk of Court Faelnar-Binongo for lack of merit, stating her role was ministerial. The Court agreed with the OCA's findings but modified the penalty.
Issue(s)
Whether respondent Judge Daomilas, Jr. is guilty of inefficiency resulting in undue delay in rendering an order. Whether respondent Clerk of Court Faelnar-Binongo is guilty of inefficiency and collusion.
Ruling
The Court found respondent Judge Ramon B. Daomilas, Jr. guilty of Undue Delay in Rendering an Order and imposed a fine of P5,000.00. The administrative charges against respondent Atty. Rosadey E. Faelnar-Binongo were dismissed for lack of merit. Judge Daomilas, Jr. was sternly warned that a repetition of the offense would be dealt with more severely.
Ratio Decidendi
On the charge against Judge Daomilas, Jr.: The Court agreed with the OCA that Judge Daomilas, Jr. demonstrated inefficiency, resulting in undue and inordinate delay in resolving the application for a writ of preliminary injunction. The November 6, 2015 Order was issued beyond the ninety (90)-day period prescribed by the Constitution for resolving pending matters. The Court emphasized that justice delayed is justice denied and that undue delay erodes public faith in the judiciary. While the Court acknowledged the judge's heavy caseload, concurrent assignments, and limited staff as mitigating circumstances, it stressed that judges must perform their duties efficiently and with reasonable promptness. The Court clarified that while the acts of a judge in his judicial capacity are generally not subject to disciplinary action unless motivated by bad faith, fraud, or corruption, the delay in this case constituted undue delay in rendering an order, a less serious charge under Rule 140 of the Rules of Court. The Court found that the errors attributed to Judge Daomilas, Jr. were not so depraved as to constitute gross ignorance of the law but were tantamount to an error of judgment, which cannot be corrected through an administrative proceeding. However, the delay itself was deemed a violation of the duty to perform judicial duties efficiently and with reasonable promptness. The Court also noted that the judge did not file a motion for extension of time to resolve the matter, which could have addressed the delay. The Court found that the judge's explanation regarding the allowance of a counter-bond was a judicial determination and not indicative of gross ignorance of the law, as the rules do not explicitly proscribe it. The Court ultimately mitigated the penalty from suspension to a fine of P5,000.00, considering the mitigating circumstances of his heavy workload and it being his first offense. On the charges against Clerk of Court Faelnar-Binongo: The Court found no merit in the administrative charges of inefficiency and collusion against Clerk of Court Faelnar-Binongo. The Court reiterated that as clerk of court, her duty to receive pleadings and motions is ministerial. She has no discretion to refuse to receive a pleading, even if it appears contrary to law or rules, as such determination is a judicial function belonging to the judge. The complainant failed to substantiate the charge of collusion. The quantum of proof required in administrative proceedings is substantial evidence, which was not met in this case. Therefore, she was exonerated from the administrative charges.
Main Doctrine
While judges are expected to act with efficiency and promptness, administrative liability for undue delay in rendering an order may be mitigated by factors such as heavy caseload and concurrent assignments, especially if the errors committed are considered errors of judgment rather than gross ignorance of the law or bad faith. Charges against court staff for performing ministerial duties, such as receiving pleadings, should be dismissed for lack of merit if not substantiated.