G.R. No. 590 - People vs Guzman

Atty. Makilito B. Mahinay filed the Complaint on April 18, 2016, before the Office of the Court Administrator (OCA).
The Complaint was directed against:

Hon. Ramon B. Daomilas, Jr., Presiding Judge, RTC Branch 11, Cebu City, Cebu; and
Atty. Rosadey E. Faelnar-Binongo, Clerk of Court V, RTC Branch 11, Cebu City, Cebu.

The allegations included gross inexcusable negligence and gross ignorance of the law in connection with the handling of SRC Case No. SRC-223-CEB.

The subject case involved plaintiffs—PJH Lending Corporation, Bernard R. Twitchett, Rosalie Canlom Farley, and Canuto T. Barte, Jr.—seeking a Judicial Declaration of Nullity of Shareholdings and praying for the issuance of a Writ of Preliminary Injunction/TRO.
The plaintiffs originally filed their complaint on December 19, 2012.
The case was raffled to RTC Branch 11, where respondent Judge Daomilas, Jr. was assigned the matter.

Atty. Mahinay alleged that Judge Daomilas, Jr. failed to act on the plaintiffs’ prayer for a TRO and the issuance of the Writ of Preliminary Injunction despite the lapse of more than two years since the case was purportedly submitted for resolution (circa March 2013).
Repeated motions and letters were submitted by the plaintiffs in an attempt to provoke an early resolution, including:

A letter dated November 3, 2015 requesting early disposition due to the protracted inaction; and
Subsequent filings, including motions, manifestos, and postings of required bonds.

On November 6, 2015, Judge Daomilas, Jr. issued an Order granting the writ of preliminary injunction subject to the posting of a bond amounting to P10,874,992.00.
Shortly thereafter, defendants filed a Motion for Reconsideration (November 12, 2015), seeking permission to post a counter-bond.
Additional orders and communications ensued, including:

Plaintiffs posting a Surety Bond on November 16, 2015 and filing their Manifestation and Compliance on November 17, 2015;
A subsequent letter from Atty. Mahinay on January 18, 2016 requesting the designation of a new judge due to the continuing delay; and
The issuance of the January 20, 2016 Order allowing defendants to file a counter-bond, which became the subject of further controversy.

A Motion to Recall/Expunge the January 20, 2016 Order was filed then later withdrawn in anticipation of a petition for mandamus and certiorari before the Court of Appeals.

Judge Daomilas, Jr. explained that his heavy workload, multiple assignments (including stations in Toledo City, Lapu-Lapu City, and Mandaue City), limited support staff, and his simultaneous assignment as Assisting Judge in Branch 55 contributed to the delay and his handling of the motions.
He asserted that his issuance of the January 20, 2016 Order was proper under Rule 58 and was done to address confusion arising from the plaintiffs’ misrepresentations regarding the case status.
Clerk Faelnar-Binongo denied any collusion, stating that receiving pleadings and motions is a ministerial duty and that she had no discretion in filtering out pleadings, even if allegedly prohibited.
Atty. Mahinay contended that the judge’s actions—including allowing the Motion for Reconsideration with a short notice for hearing and failing to promptly issue the writ of preliminary injunction—amounted to gross ignorance of the law and constituted administrative misconduct.

The OCA, in a Memorandum dated February 12, 2018, found that Judge Daomilas, Jr. committed an undue delay by issuing the November 6, 2015 Order beyond the mandatory 90-day period set by the Constitution (from the filing of the last pleading).
The OCA noted that such delay was inexcusable unless the judge had filed a proper motion for an extension of time, citing his heavy workload.
Based on mitigating circumstances such as his heavy caseload and the fact that this was his first administrative offense, the OCA recommended reducing the penalty to a reprimand.
For the clerk, the administrative charges of inefficiency and collusion were dismissed for lack of merit.

Whether Judge Daomilas, Jr.’s conduct in delaying the issuance of the writ of preliminary injunction, taking more than two years to act, constitutes gross inexcusable negligence.
Whether such delay violates the constitutional mandate requiring cases to be resolved within prescribed periods (90-day period under Article 8 of the 1987 Constitution).

Whether allowing defendants to file a counter-bond and setting the Motion for Reconsideration on a shortened notice was proper.
Whether this action represents a judicial error or amounts to gross ignorance of the law.

Whether Clerk Faelnar-Binongo colluded with Judge Daomilas, Jr. in delaying the resolution of the case by accepting an allegedly prohibited pleading.
Whether the actions of the clerk fall within her ministerial duties, thus absolving her of administrative liability.

Whether Judge Daomilas, Jr.’s heavy workload and multiple responsibilities justify or mitigate his delay and the subsequent administrative sanctions.

To what extent should administrative sanctions be imposed on a judge for errors committed in the exercise of judicial functions if done in good faith.
Whether administrative proceedings are the proper forum to address judicial errors that, although erroneous, may not involve bad faith, fraud, or corruption.