G.R. No. 94-1150, June 5, 1995
Spouses Julio V. Cui and Aresia Obsioma-Cui, complainants, vs. Judge Job B. Madayag, RTC, Br. 145, Makati, respondent.

FACTS

Complainants, as legal guardians of the plaintiffs in two consolidated civil cases, charged respondent Judge with ignorance of the law, grave misconduct, and oppression. The charges stemmed from the judge’s handling of motions to lift a preliminary injunction and to dismiss the cases. A critical procedural lapse occurred when the defendants’ motion to lift the injunction, which lacked the requisite proof of service to the plaintiffs, was nonetheless set for hearing by the judge. The notice of this hearing was mailed late, resulting in plaintiffs receiving it only after the scheduled date. Despite plaintiffs’ non-appearance due to this defective notice, the judge allowed the defendants to argue their motion ex-parte and subsequently issued an order dissolving the injunction. Complainants further alleged that the judge improperly allowed the defendants to present evidence ex-parte on their motion to dismiss, which was based on grounds like lack of cause of action, and later considered this evidence even though no formal offer was made.

ISSUE

Whether respondent Judge is administratively liable for his procedural actions in handling the motions to lift the injunction and to dismiss the cases.

RULING

Yes, the Supreme Court found respondent Judge administratively liable. The legal logic is anchored on the violation of specific procedural rules and canons of judicial conduct. First, the judge disregarded Section 6, Rule 15 of the Rules of Court by acting on a motion that lacked proof of service, a mandatory requirement for a valid hearing. His act of setting the motion for hearing and resolving it ex-parte despite the defective service constituted ignorance of this fundamental procedural rule. Second, the delayed service of the notice of hearing, which the judge attributed to court personnel inadvertence, demonstrated a failure in his duty under Canon 3, Rule 3.09 of the Code of Judicial Conduct to diligently supervise court personnel and ensure the efficient administration of court business. While the Court found no conclusive evidence of bias or bad faith to substantiate charges of grave misconduct and oppression, the judge’s procedural lapses and failure of supervision warranted administrative sanction. Consequently, the Court imposed a fine and issued a reprimand with a stern warning, emphasizing that a judge must maintain strict adherence to procedural due process and effective court management.