G.R. No. MTJ-02-1461. March 31, 2005
MA. TERESA D. COLUMBRES, Complainant, vs. JUDGE ANICETO L. MADRONIO, Respondent.

FACTS

Complainant Ma. Teresa D. Columbres was the defendant in a forcible entry case filed by her stepmother, Lucille S. Columbres, before the Municipal Circuit Trial Court (MCTC) of San Fabian-San Jacinto, Pangasinan, presided by Judge Aniceto L. Madronio. The plaintiff filed a motion for a writ of preliminary mandatory injunction to regain possession of the disputed premises. Despite the complainant filing an opposition, Judge Madronio granted the plaintiff’s subsequent urgent ex-parte motion for the writ via a handwritten notation on December 14, 1999, and formalized the writ on December 16, 1999. The writ ordered the complainant to restore possession of the premises and to refrain from carting away personal belongings, specifically mentioning a Volkswagen car. The complainant filed a motion to lift the writ and to reconsider the order concerning the car on January 20, 2000, arguing the car was not involved in the suit. As of her complaint letter dated June 8, 2001, this motion remained unresolved.

ISSUE

Whether Judge Madronio is administratively liable for his actions in connection with Civil Case No. 1014 (SJ-99).

RULING

Yes, Judge Madronio is administratively liable for grave abuse of discretion and gross inefficiency. The Supreme Court found that the judge committed a grave abuse of authority by issuing the writ of preliminary mandatory injunction without a hearing. A preliminary mandatory injunction, which commands the performance of a particular act, is a drastic remedy that should only be granted after a hearing where both parties are given the opportunity to present evidence. The judge’s act of granting the writ based solely on an ex-parte motion and an opposition, without conducting a hearing, was a patent violation of procedural rules. Furthermore, the writ improperly included an order concerning a Volkswagen car, a matter not pleaded in the forcible entry complaint, thereby exceeding the scope of the action.
The Court also found the judge guilty of gross inefficiency for his undue delay in resolving the complainant’s motion to lift the injunction. The motion remained unacted upon for over seventeen months, a clear violation of the constitutional mandate for the speedy disposition of cases. Such delay undermines public confidence in the judiciary. Considering the infractions and noting that Judge Madronio had already retired, the Court imposed a fine of Ten Thousand Pesos (P10,000.00), to be deducted from his withheld retirement benefits.