The Supreme Court in Dela Paz v. Adiong addressed the critical issue of judicial overreach, specifically concerning the territorial limits of a Regional Trial Court’s (RTC) authority to issue and enforce writs of injunction. The Court firmly established that an RTC’s injunctive powers are confined within its respective judicial region. This ruling safeguards against the abuse of authority and ensures that judicial actions remain within legally prescribed boundaries, protecting individuals and entities from potentially overreaching court orders.

When a Judge’s Reach Exceeds His Grasp: The Saga of an Overzealous Injunction

This case arose from a complaint filed against Judge Santos B. Adiong of the Regional Trial Court (RTC) of Marawi City, Branch 8, by Gabriel dela Paz, an officer-in-charge of the Fund for Assistance to Private Education (FAPE). Dela Paz alleged gross ignorance of the law and abuse of authority on the part of Judge Adiong. The controversy stemmed from Special Civil Action No. 813-02, a petition for mandamus filed by Pacasum College, Inc. against FAPE. The core issue revolved around an order issued by Judge Adiong requiring FAPE to release P4,000,000.00 to Pacasum College, Inc., coupled with directives for its enforcement outside his judicial region.

At the heart of the matter was the scope of the RTC’s authority to issue writs enforceable beyond its territorial jurisdiction. The complainant contended that the respondent judge’s issuance of a writ of preliminary mandatory injunction was a blatant disregard of Section 21 of Batas Pambansa Blg. 129, which delineates the authority of RTCs to issue writs of mandamus within their respective regions. Additionally, the complainant pointed out the respondent judge’s continued issuance of orders directing FAPE to release funds even in a case where it was not a party, as well as the disregard of notice and hearing requirements under Rule 58 of the Rules of Court.

In his defense, the respondent judge explained that he had already ordered the dismissal of Special Civil Action No. 813-02 and had recalled his questioned orders. He argued that with the dismissal of the case, the complaint had become moot and academic. However, the complainant countered that FAPE’s counsel was not furnished with a copy of the respondent’s resolution dismissing the case, and that there was still a pending motion for reconsideration. Complainant insisted that their complaint should be addressed.

The Supreme Court, after careful consideration, found Judge Adiong guilty of gross ignorance of the law and abuse of authority. The Court emphasized that Judge Adiong’s issuance of the writ of preliminary mandatory injunction dated March 4, 2002, was in glaring disregard of Section 21 of B.P. Blg. 129. The Court held that RTCs could only enforce their writs of injunction within their respective designated territories. The Court noted that FAPE was not even a party in the Corporate Case No. 010 when the respondent issued another order.

SEC. 21. Original Jurisdiction in other cases. – Regional Trial Courts shall exercise original jurisdiction:
(1) In the issuance of writs of certiorari, prohibition, mandamus, quo warranto, habeas corpus and injunction which may be enforced in any part of their respective regions;

The Court found that Judge Adiong had overstepped his jurisdictional bounds by attempting to enforce the writ in Makati City, which is outside his judicial region. The Court highlighted the importance of adherence to procedural rules, particularly the mandatory requirement of notice and hearing before granting a preliminary injunction. Furthermore, the Court took note of the fact that respondent judge had been previously penalized twice. The Court reiterated that “Regional Trial Courts can only enforce their writs of injunction within their respective designated territories.”

Building on this principle, the Court underscored that even the subsequent dismissal of the special proceeding did not render the administrative complaint moot and academic. The heart of the issue was the respondent judge’s violation of the law, amounting to ignorance of the law or procedure. The Court thus affirmed the recommendation of the Court Administrator to impose a penalty on the respondent judge. Because of his previous violations, the Court ruled Judge Adiong should be suspended for a period of six months without pay.

FAQs

What was the key issue in this case?	The key issue was whether Judge Adiong exceeded his authority by issuing a writ of preliminary mandatory injunction enforceable outside his judicial region. The Court addressed the territorial limitations of an RTC’s power to issue writs of injunction.
What is a writ of preliminary mandatory injunction?	A writ of preliminary mandatory injunction is a court order that commands a party to perform a specific act before a full trial on the merits of the case. It is an extraordinary remedy granted only when the applicant demonstrates a clear legal right and an urgent necessity.
What is the territorial limit of an RTC’s authority to issue a writ of injunction?	Under Section 21 of B.P. Blg. 129, an RTC’s authority to issue writs of injunction extends only to acts performed or about to be performed within its respective judicial region. It does not have the power to issue writs enforceable beyond its territorial boundaries.
Why was the judge found guilty of gross ignorance of the law?	Judge Adiong was found guilty because he disregarded Section 21 of B.P. Blg. 129 and Rule 58 of the Rules of Court by issuing a writ of preliminary mandatory injunction enforceable outside his judicial region without proper notice and hearing. His actions showed a clear lack of familiarity with basic legal principles.
What is the significance of the notice and hearing requirements for preliminary injunctions?	The notice and hearing requirements ensure that the party sought to be enjoined has an opportunity to be heard and present their side of the story before the injunction is issued. This safeguards against arbitrary or unjust orders.
What penalty did the judge receive?	Judge Adiong was suspended for a period of six (6) months without pay. The suspension came with a warning that any similar future conduct would warrant his dismissal from the service.
What was FAPE’s role in this case?	FAPE (Fund for Assistance to Private Education) was the entity against whom the writ of preliminary mandatory injunction was issued, ordering them to release funds. As such, they were the respondent in the original special civil action.
Does the dismissal of the original case render the administrative case moot?	No, the Supreme Court clarified that the administrative case against Judge Adiong was not rendered moot by the dismissal of the original special civil action. The administrative case focused on the judge’s violation of the law and procedure, which remained relevant regardless of the case’s outcome.

The Supreme Court’s decision in this case serves as a crucial reminder to judges to exercise their authority within the bounds of the law. By reaffirming the territorial limits of an RTC’s injunctive power and emphasizing the importance of procedural due process, the Court has reinforced the principles of fairness, justice, and judicial accountability within the Philippine legal system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Dela Paz v. Adiong, A.M. No. RTJ-04-1857, November 23, 2004