AM RTJ 04 1889; (December, 2004) (Digest)
A.M. No. RTJ-04-1889. December 22, 2004. MA. CECILIA L. PESAYCO, complainant, vs. JUDGE WILLIAM M. LAYAGUE, RTC, Branch 14, Davao City, respondent.
FACTS
Atty. Ma. Cecilia L. Pesayco, as Chief Legal Counsel of PNB, filed an administrative complaint against Judge William M. Layague for gross ignorance of the law, manifest partiality, and inefficiency. The complaint stemmed from Civil Case No. 29,036-2002, a petition for declaratory relief with a prayer for injunction filed by spouses Limso against PNB concerning a foreclosure redemption period. Judge Layague initially issued a TRO without a hearing but promptly recalled it. He later granted the writ of preliminary injunction. While he was on leave, a pairing judge dissolved this writ. Upon returning, Judge Layague reinstated his original order granting the injunction, allegedly making biased remarks against the pairing judge’s order. PNB filed a motion to inhibit, which was not acted upon before the reinstatement order.
Complainant also alleged Judge Layague failed to resolve a motion for reconsideration in a different PNB case for nearly a year, exceeding the reglementary period. She accused the judge of various procedural errors, including not requiring a re-raffle upon the amendment of the complaint to include injunctive relief and denying PNB’s motion to dismiss without a separate hearing.
ISSUE
Whether Judge William M. Layague is administratively liable for gross ignorance of the law, manifest partiality, and inefficiency.
RULING
The Supreme Court found Judge Layague liable for INEFFICIENCY but NOT for gross ignorance of the law or manifest partiality. The charges of gross ignorance were based on his judicial actions, such as granting the injunction and procedural handling of the raffle and motions. The Court emphasized that for such a serious charge to prosper, the error must be gross, deliberate, and malicious, showing bad faith. Judge Layague’s errors, while potentially incorrect, were not shown to be motivated by bad faith, fraud, or corruption. His immediate correction of the erroneous TRO issuance demonstrated a lack of deliberate intent to violate the law.
However, the Court upheld the charge of inefficiency for his failure to resolve a pending motion for reconsideration in another case within the mandatory 90-day period. This undue delay constitutes a violation of the Code of Judicial Conduct and undermines public confidence in the judiciary. The Court considered his claim of a heavy workload but noted it is not a valid excuse for failing to comply with reglementary periods. For this inefficiency, he was fined Five Thousand Pesos (P5,000.00) with a stern warning.