A.M. No. RTJ-05-1910. April 15, 2005.
Alfredo Hilado, Lopez Sugar Corporation and First Farmers Holding Corporation, Complainants, vs. Judge Amor A. Reyes, Regional Trial Court of Manila, Branch 21, Respondent.

FACTS

Complainants, as major creditors of the late Roberto S. Benedicto, filed an administrative complaint against Judge Amor A. Reyes for gross ignorance of the law and serious misconduct in handling Special Proceedings No. 00-97505 for the issuance of letters of administration. They alleged that the administratrix appointed by the judge failed to submit a verified, complete inventory and an annual accounting as mandatorily required by the Rules of Court. Further, the judge approved the sale of substantial estate assets without notice to the known creditors, specifically excluding the complainants’ claims from the liabilities assumed by the purchaser.
Despite the administratrix’s own inventory listing the complainants as major creditors, her petition for letters of administration did not name any creditors. Consequently, no notices were served on the complainants as required by Rule 79. When the complainants filed a manifestation and subsequent motions to intervene and to compel compliance with the rules, Judge Reyes issued an order refusing to recognize them as interested parties with legal standing to participate in the proceedings, effectively precluding their involvement.

ISSUE

Whether respondent Judge Amor A. Reyes is administratively liable for gross ignorance of the law and serious misconduct in her handling of the intestate estate proceedings.

RULING

Yes, the Supreme Court found Judge Reyes guilty of gross ignorance of the law and imposed a fine of P40,000. The legal logic is clear: a judge’s duty to be proficient in the law is paramount, and failure to apply fundamental rules constitutes gross ignorance. The Rules on settlement of estates are explicit. Rule 79, Sections 2 and 3 require the petition for letters of administration to name known creditors and for notice to be given to them. Rule 85 mandates the submission of an annual account, and Rule 89 governs the sale of estate assets with notice to interested persons.
Judge Reyes disregarded these elementary and mandatory procedures. By allowing the administratrix to proceed without naming creditors and by approving asset sales without notice to the acknowledged major claimants, she deprived the complainants of their statutory right to be heard and to protect their interests. Her subsequent order denying their intervention, despite clear evidence of their status as major creditors, demonstrated a persistent disregard for settled law. This pattern of error transcended mere fallible judgment; it revealed a lack of familiarity with basic legal rules that a judge presiding over a probate court is duty-bound to know. Such incompetence undermines public confidence in the judiciary and warrants administrative sanction.