Short answer. Within twenty-four hours. Rule 58, Section 4(d) requires the court to act on a TRO application only after a summary hearing where all parties are heard, and that hearing must be conducted within twenty-four hours after the sheriff's return of service and/or after the records reach the branch selected by raffle.
What the law says
The application for a temporary restraining order shall thereafter be acted upon only after all parties are heard in a summary hearing which shall be conducted within twenty-four hours after the sheriff's return of service and/or the records are received by the branch selected by raffle and to which the records shall be transmitted immediately.
Rule 58, Section 4 — Verified application and bond for preliminary injunction or temporary restraining order. Read the full provision →
The twenty-four-hour hearing deadline
Rule 58, Section 4(d) provides that an application for a temporary restraining order shall be acted upon only after all parties are heard in a summary hearing, and that this hearing shall be conducted within twenty-four hours after the sheriff's return of service and/or the records are received by the branch selected by raffle and to which the records are transmitted immediately. The clock is tied to whichever of these events actually triggers it, not to a fixed calendar date set when the TRO application was first filed.
Why the deadline is framed around two triggers
The rule names two possible starting points because a TRO application can reach the hearing stage from two directions: the sheriff completing service and filing a return, or the case records physically arriving at the branch the raffle assigned. Framing the deadline around 'and/or' rather than a single trigger means the twenty-four-hour clock runs from whichever of these events supplies the court with what it needs to proceed, rather than requiring both to happen in a particular order first.
Notice and service that come before the hearing
Before this hearing can happen, the rule requires notice to, and generally service of summons upon, the adverse party — together with the complaint or initiatory pleading and the applicant's affidavit and bond — preceding or accompanying that notice. An exception exists where summons could not be served personally or by substituted service despite diligent efforts, or where the adverse party is temporarily absent from or a nonresident of the Philippines; in those situations the requirement of prior or contemporaneous service does not apply.
What the hearing itself must be
The rule describes this hearing as summary — a hearing where all parties are heard, but structured to move quickly given how urgent TRO relief typically is. This is distinct from the fuller proceedings that may follow if the case later moves toward a preliminary injunction, which carries its own verification, bond, and approval requirements under the earlier parts of the same section.