Facts:

This case, G.R. No. 84324, concerns a special civil action for certiorari filed by Santiago Aquino, Terencio Yumang, Jr., and Fulgencio Icaro, hereinafter referred to as the petitioners, against Hon. Guillermo R. Luntok, presiding judge of the Regional Trial Court, Branch XXIX of Libmanan, Camarines Sur, and Ludovico B. Peralta, the private respondent. The events transpired between August and November of 1987, centering on Civil Case No. L-361. The private respondent, acting as the Municipal Treasurer of Libmanan, was found by the petitioners—who were government auditors—to have a cash shortage amounting to P274,011.17. Subsequently, an audit and seizure of his properties were conducted, leading to the respondent's suspension from office. In response, Peralta filed a petition for prohibition along with a request for an injunction to halt the auditors' actions against him. The presiding judge issued multiple temporary restraining orders (TROs) starting August 27, 1987, wi

...

Facts:

Background of the Case

• Petitioners, acting in their official capacities (Provincial Auditor, State Auditor I, and State Examiner of the Provincial Auditor’s Office), conducted an audit on the accounts of private respondent, who was serving as Municipal Treasurer of Libmanan, Camarines Sur, and discovered a cash shortage amounting to ₱274,011.17.
• Based on findings from the audit, petitioners, pursuant to Section 157 of Batas Pambansa Blg. 337, seized private respondent’s cash, books, papers, and accounts, which resulted in his suspension from office.
• Private respondent, following his suspension, requested a reinvestigation by the Commission on Audit.

Initiation of Judicial Proceedings

• On August 26, 1987, private respondent filed a petition with the Regional Trial Court of Camarines Sur (Branch XXIX) seeking prohibition with injunction, a restraining order, and damages.
• Respondent judge immediately issued a Temporary Restraining Order (TRO) on August 27, 1987, enjoining the petitioners and their representatives from taking any action against private respondent related to the audit report for a period of 20 days.

Series of Issuances and Extensions by the Trial Court

• On September 16, 1987 – the last day of the TRO’s initial 20-day effectivity – the court extended the TRO for an additional 20-day period, lasting until October 6, 1987.
• On October 6, 1987, while the extended TRO was still in effect, the trial court issued an order directing petitioners to refrain from further actions until a motion for extension was resolved.
• On September 24, 1987, upon the motion of private respondent, the court directed petitioners to return the seized cash, books, and papers; petitioners subsequently filed a motion for reconsideration of this directive.
• On October 27, 1987, petitioners commenced an original action for certiorari in the Court of Appeals challenging the validity of the TROs issued on August 27, September 16, and October 6, 1987.
• While the petition in the Court of Appeals was pending, respondent judge granted a writ of preliminary injunction on November 4, 1987, following a motion and subsequent hearing.
• The next day, November 5, 1987, the trial court approved the bond filed by private respondent, which led to the issuance of the writ on November 11, 1987.
• The Court of Appeals later dismissed the petition for certiorari on May 11, 1988 on grounds of mootness, as the writ of preliminary injunction had already been granted.

Core Points Raised by the Petitioners

• Petitioners challenged the validity of the writ of preliminary injunction issued on November 11, 1987, arguing it amounted to a fourth restraining order purporting to restrain the same act after the TRO’s prescribed 20-day period had lapsed.
• They further contended that the issuance of the injunction was in disregard of the doctrine requiring exhaustion of administrative remedies, since private respondent still had a pending request for reinvestigation with the Commission on Audit.
• Petitioners argued that the chain of orders, particularly those issued after the expiration of the TRO’s effectivity, were procedurally and legally flawed.

Issue:

Validity of the Writ of Preliminary Injunction

• Whether the issuance of a writ of preliminary injunction outside the 20-day effectivity period of a TRO is valid, once the extended TRO has expired or been rendered functus officio.
• Whether issuing a preliminary injunction, effectively substituting for successive restraining orders, cures any defect arising from the extended application of the TRO beyond its statutory period.

Application of the Doctrine on Exhaustion of Administrative Remedies

• Whether private respondent’s invocation of the urgency of judicial intervention constitutes a recognized exception to the general rule mandating exhaustion of administrative remedies before resorting to the courts.
• Whether the pending request for reinvestigation with the Commission on Audit should have precluded the issuance of the preliminary injunction.

Judicial Conduct and Procedural Compliance

• Whether the respondent judge adhered to the provisions of the Rules of Court, particularly Rule 58 and other prescribed guidelines, including the requirements for notice and hearing in the issuance of injunctions.
• Whether the delay and series of orders by the respondent judge amounted to an abuse of discretion or violation of judicial ethical standards (specifically Rules 3.01 and 3.05 of the Code of Judicial Conduct).

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)