A.M. No. RTJ-04-1889 - Pesayco vs. Layague

The administrative case arose from an Affidavit-Complaint filed by Atty. Ma. Cecilia L. Pesayco, Chief Legal Counsel of the Philippine National Bank (PNB), against Judge William M. Layague of the Regional Trial Court (RTC), Branch 14, Davao City.
The complaint charged Judge Layague with gross ignorance of the law, knowingly rendering an unjust interlocutory order, manifest partiality, unreasonable delay in resolving pending incidents, and serious misconduct.

The spouses Robert Alan and Nancy Limso filed a civil case for declaratory relief, seeking a preliminary injunction and challenging the constitutionality of Republic Act No. 8791 (General Banking Law of 2000).
They argued that the redemption period should be governed by Act 3135, which provides a one-year redemption period, rather than R.A. No. 8791.
PNB was not notified of the raffle of the case. The spouses Limso later amended their complaint to include a prayer for a Temporary Restraining Order (TRO).

On April 10, 2002, Judge Layague issued a TRO without conducting a hearing. He later reversed this order on April 16, 2002, after realizing his mistake.
PNB filed a Motion to Dismiss, opposing the issuance of a preliminary injunction and TRO, citing forum-shopping, lack of cause of action, and lack of locus standi by the spouses Limso.
On May 3, 2002, Judge Layague granted the writ of preliminary injunction in favor of the spouses Limso. PNB filed a Motion for Reconsideration, which was resolved by a pairing judge in favor of PNB, dissolving the injunction.

Judge Layague returned from leave and reinstated the writ of preliminary injunction on June 24, 2002, despite PNB's Motion to Inhibit.
Pesayco alleged that Judge Layague showed bias and partiality, particularly when he expressed misgivings about the pairing judge's order and reinstated the injunction.

Pesayco accused Judge Layague of failing to resolve a Motion for Reconsideration filed by PNB in another case (Civil Case No. 28,469-2001) for 17 months, constituting inefficiency.

Violation of Section 4(c), Rule 58: The Court agreed with the Office of the Court Administrator (OCA) that Judge Layague failed to comply with Section 4(c), Rule 58, which requires notice to the adverse party when a complaint is amended to include a prayer for a TRO. However, the Court noted that there was no clear rule or jurisprudence mandating re-raffling in such cases, and Judge Layague's actions did not indicate bad faith or gross ignorance of the law.
Gross Ignorance of the Law: The Court emphasized that not every mistake in the application of the law constitutes gross ignorance. Liability attaches only when the judge acts with bad faith, dishonesty, or malice. In this case, Judge Layague's errors were not shown to be motivated by such improper motives.
Inefficiency: The Court found Judge Layague guilty of inefficiency for the unreasonable delay in resolving PNB's Motion for Reconsideration. Judges are required to dispose of cases promptly, and failure to do so constitutes a violation of the Code of Judicial Conduct. The delay of 17 months was deemed excessive and warranted administrative sanction.
Judicial Indolence: The Court reiterated that judicial indolence is a serious offense and that judges must request extensions if they cannot resolve cases within the prescribed period. Judge Layague's failure to do so, coupled with his delay, justified the imposition of a fine.

Judge Layague was fined P5,000.00 for inefficiency, with a warning against future offenses. The other charges were dismissed for lack of evidence of bad faith or malice.