G.R. No. RTJ-25-084. February 18, 2025.
HON. JOSEFINA B. TALLADO, COMPLAINANT, vs. PRESIDING JUDGE WINSTON S. RACOMA, BRANCH 39, REGIONAL TRIAL COURT, DAET, CAMARINES NORTE, AND PRESIDING JUDGE ARNIEL A. DATING, BRANCH 41, REGIONAL TRIAL COURT, DAET, CAMARINES NORTE, RESPONDENTS.

FACTS

Complainant Hon. Josefina B. Tallado, a Representative, requested a judicial audit of the courts presided by respondents Judge Winston S. Racoma and Judge Arniel A. Dating based on reports of anomalous issuances of temporary restraining orders (TROs) and cases heard irrespective of jurisdiction. The Office of the Court Administrator (OCA) conducted an audit. The audit revealed that: (1) Judge Racoma issued 20-day TROs in SP Civil Case Nos. 8484 and 8513 without conducting the required summary hearing, in violation of Administrative Circular No. 20-95 and Section 5, Rule 58 of the Rules of Court; and (2) Both Judge Racoma and Judge Dating failed to submit copies of issued TROs as required by Administrative Order No. 63-2020. The OCA opined that Judge Racoma’s failure constituted gross ignorance of the law. In their comments, both judges attributed their non-compliance with A.O. No. 63-2020 to inadvertence, heavy workload, and disruptions due to the COVID-19 public health emergency. Judge Racoma further contended that the administrative complaint was part of a concerted effort by public officials, including the complainant’s husband (Governor Edgardo Tallado, who was a respondent in the cases where TROs were issued), to harass and intimidate him due to his judicial actions. The Office of the Executive Director (OED) of the Judicial Integrity Board (JIB) recommended dismissal of the complaint, finding it involved judicial issues and lacked merit. The Judicial Integrity Board, however, recommended that Judge Racoma be found guilty of gross ignorance of the law and be fined P40,000, while the complaint against Judge Dating be dismissed.

ISSUE

Whether respondents Judge Winston S. Racoma and Judge Arniel A. Dating should be held administratively liable based on the findings of the judicial audit.

RULING

The Court adopted the findings and recommendation of the Judicial Integrity Board.
1. As to Judge Racoma: He was found GUILTY of GROSS IGNORANCE OF THE LAW for issuing 20-day TROs without conducting the mandatory summary hearing, in violation of Administrative Circular No. 20-95 and Section 5, Rule 58 of the Rules of Court. His defense that the administrative cases were filed to harass him was unavailing, as the procedural lapse was clear. The Court imposed a FINE of FORTY THOUSAND PESOS (P40,000), with a stern warning that a repetition of the same or similar act would be dealt with more severely.
2. As to Judge Dating: The complaint against him was DISMISSED. His failure to comply with Administrative Order No. 63-2020 (submission of TRO copies) was not attended by bad faith, being attributable to the delayed receipt of the order and the extraordinary circumstances of the COVID-19 pandemic. His explanation was accepted, and he was merely ADMONISHED to be more diligent in complying with administrative issuances.
The Court emphasized that judges must be conversant with basic legal principles and procedural rules. The issuance of a TRO without a summary hearing, except in specific, urgent circumstances, is a fundamental procedural error that constitutes gross ignorance of the law. The Court also noted that administrative complaints should not be used as tools for harassment against judges who issue unfavorable orders, but such a motive does not exonerate a judge from liability for clear violations of established rules.