A.M. No. RTJ-01-1645; August 28, 2001
Victorino S. Sianghio, Jr., petitioner, vs. Judge Bienvenido L. Reyes, RTC-Branch 74, Malabon, Metro Manila, respondent.

FACTS

Complainant Victorino Sianghio, Jr. filed an ejectment case against lessees, including Nestor Lazaro. The case progressed through the MeTC, RTC, Court of Appeals, and Supreme Court, with all courts ultimately ruling in Sianghio’s favor and ordering execution. After the Supreme Court remanded the case for execution, Lazaro, using an association as petitioner, filed a petition for prohibitory injunction with a prayer for a Temporary Restraining Order (TRO) before the RTC of Malabon. This petition was raffled to Branch 74, presided by respondent Judge Bienvenido Reyes.
Sianghio alleged that Judge Reyes issued an ex-parte TRO against the execution, violating Administrative Circular No. 20-95. Sianghio then filed a motion to dismiss the injunction petition. The judge set the motion for hearing and required the submission of comments. However, after the association filed its comment, Judge Reyes took no action on the motion to dismiss for nearly eight months. Sianghio contended this inaction was a deliberate delay to benefit the defendants.

ISSUE

Whether respondent Judge Bienvenido L. Reyes is administratively liable for the alleged issuance of an improper TRO and for the undue delay in resolving a pending motion.

RULING

The Court, adopting the findings of the Deputy Court Administrator, dismissed the charge regarding the TRO for lack of merit. An investigation of the case records revealed that Judge Reyes did not, in fact, issue any restraining order in the subject civil case. Therefore, the allegation was unsubstantiated.
However, the Court found Judge Reyes administratively liable for undue delay. He admitted the motion to dismiss remained unresolved for over eight months, attributing the delay to the case records being “misplaced.” The Court rejected this justification. Judges have a sworn duty to dispose of court business promptly and to ensure efficient record management under their supervision. The failure to locate the records for an extended period, without a showing of diligent effort to find them until a routine inventory was conducted, constitutes negligence and poor court administration. This delay deprived the litigant of a speedy disposition and undermined public confidence in the judiciary.
Consequently, the Court ADMONISHED Judge Reyes to exercise greater diligence and dispatch in acting on cases and WARNED that a repetition would be dealt with more severely. The other charges were dismissed for lack of merit.