A.M. No. RTJ-07-2035 ; June 12, 2008
China Banking Corporation, represented by Margarita L. San Juan and George C. Yap, complainant, vs. Judge Leoncio M. Janolo, Jr., Regional Trial Court, Br. 264, Pasig City, respondent.

FACTS

China Banking Corporation filed an administrative complaint against Judge Leoncio M. Janolo, Jr. for simple misconduct and undue delay in rendering orders in Civil Case No. 68105. The case involved a complaint by Solid Builders, Inc. and Medina Food Industries, Inc. seeking to restrain the bank from foreclosure and to assail interest rates. Judge Janolo granted a writ of preliminary injunction in December 2000. China Bank filed a motion for reconsideration in February 2001, which the judge denied in December 2001. The bank later filed a motion to dissolve the injunction in February 2003, which was denied in November 2003.
After China Bank’s motion to dismiss the civil case was denied in January 2005, Judge Janolo took no further action on the case for over a year. The last pleading was filed in October 2004, and by the time China Bank filed its administrative complaint in November 2005, the judge had unjustifiably left the case dormant. The Office of the Court Administrator found the judge liable for undue delay in resolving the two earlier motions and recommended a fine.

ISSUE

Whether Judge Leoncio M. Janolo, Jr. is administratively liable for simple misconduct and undue delay in rendering orders.

RULING

Yes, Judge Janolo is administratively liable. The Court found him guilty of both undue delay in rendering orders and simple misconduct. Regarding undue delay, the judge violated specific timeframes for resolving motions. For the motion for reconsideration filed in February 2001, the Rules of Court require resolution within 30 days from submission. The last pleading was filed in October 2001, making the order due by November 2001. Judge Janolo issued his denial on December 10, 2001, an 18-day delay. For the motion to dissolve filed in February 2003, the Constitution mandates resolution within three months from the last pleading filed in May 2003. The order was due by August 2003 but was issued on November 10, 2003, a delay of over two months.
Furthermore, his failure to act on the main case for more than a year after the last pleading constituted simple misconduct, defined as a transgression of an established rule of action through unlawful behavior or negligence. This demonstrated a lack of dedication to judicial duty. Considering this was his third offense, the Court imposed a fine of P20,000, exceeding the OCA’s initial recommendation, and issued a stern warning. The Court emphasized that judges must perform duties efficiently and promptly to maintain public confidence in the judiciary.