Facts:

The case involves Governor Mahid M. Mutilan as the petitioner and Judge Santos B. Adiong of the Regional Trial Court, Branch 8, Marawi City, as the respondent. The administrative complaint was filed on July 2, 2002, stemming from a civil case, SPC Civil Case No. 507-98, which was initiated by several petitioners against the Province of Lanao del Sur, Governor Mutilan, and other officials regarding unpaid salaries. The complaint alleged that Judge Adiong exhibited gross ignorance of the law, incompetence, and violated the Anti-Graft and Corrupt Practices Act.

The events unfolded when Judge Adiong assumed jurisdiction over the case without conducting a raffle and issued an order requiring the provincial government to respond within ten days, despite the petition not being served to the complainant. On September 24, 1998, Judge Adiong declared the respondents in default after the provincial government failed to respond. Subsequently, on October 5, 1998, he rendered a judgment...

Facts:

1. Parties Involved:

   • Complainant: Governor Mahid M. Mutilan of the Province of Lanao del Sur.
   • Respondent: Judge Santos B. Adiong of the Regional Trial Court (RTC), Branch 8, Marawi City.

2. Root Case:

   • The administrative complaint arose from SPC Civil Case No. 507-98, a mandamus and damages case filed by several petitioners against the Province of Lanao del Sur, Governor Mahid M. Mutilan, and other officials. The petitioners sought payment of their unpaid salaries and other benefits.

3. Allegations Against Judge Adiong:

   • Governor Mutilan alleged that Judge Adiong:
     • Assumed jurisdiction over the case without conducting a raffle.
     • Issued an order requiring the provincial government to answer the petition within 10 days without proper service of the petition.
     • Declared the respondents in default without proper notice.
     • Rendered a judgment by default ordering the provincial government to pay the petitioners P562,966.93 for unpaid salaries, P500,000.00 for moral damages, P30,000.00 for attorney’s fees, and costs.
     • Granted a motion for garnishment of the provincial government’s funds without proper notice to the adverse party.

4. Key Events:

   • On 24 September 1998, Judge Adiong granted the petitioners’ motion to declare the respondents in default.
   • On 5 October 1998, Judge Adiong rendered a judgment by default, which was promulgated on 6 October 1998.
   • On 6 October 1998, the petitioners filed a joint motion for garnishment, which Judge Adiong granted on the same day.
   • On 8 October 1998, the petitioners filed a motion for contempt, and Judge Adiong ordered the Philippine National Bank (PNB) to release the garnished funds.
   • The provincial government, through its counsel, filed a motion to set aside the order of default, but Judge Adiong proceeded with the judgment and garnishment.

5. Respondent Judge’s Defense:

   • Judge Adiong denied the allegations, stating that:
     • A raffle was conducted, and the case was properly assigned to him.
     • The provincial government was duly served with the order to answer the petition.
     • The respondents were declared in default for failing to file an answer within the reglementary period.
     • He did not benefit from the garnished funds.

6. Investigation Findings:

   • The Office of the Court Administrator (OCA) found that Judge Adiong ignored established rules and legal principles.
   • The Investigating Justice found that:
     • The motion to declare the respondents in default lacked proof of service and proper notice of hearing.
     • The joint motion for garnishment was defective as it did not notify the adverse party.
     • Judge Adiong acted on these motions without ensuring compliance with procedural rules.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Gross Ignorance of the Law:

   • Judge Adiong failed to comply with the 1997 Rules of Civil Procedure, particularly:
     • Rule 15, Section 6: Proof of service is mandatory for motions.
     • Rule 15, Section 5: Notice of hearing must be addressed to all parties concerned.
     • Rule 39, Section 2(a): Discretionary execution (e.g., garnishment) requires notice to the adverse party.
   • Judge Adiong acted on defective motions (motion to declare default and motion for garnishment) without ensuring proper notice and proof of service. This demonstrated a lack of familiarity with procedural rules.

2. Violation of Due Process:

   • By declaring the respondents in default and granting garnishment without proper notice, Judge Adiong deprived the provincial government of its right to be heard. This violated the fundamental principle of due process.

3. No Violation of Anti-Graft and Corrupt Practices Act:

   • There was no evidence that Judge Adiong benefited from the garnished funds. Thus, the charge of violating the Anti-Graft and Corrupt Practices Act was dismissed.

4. Judicial Competence and Integrity:

   • Judges are expected to be proficient in the law and to keep abreast of legal developments. Ignorance of the law erodes public confidence in the judiciary. Judge Adiong’s actions demonstrated a lack of competence and familiarity with procedural rules, warranting administrative sanctions.