Caguioa v. Laviña
REITERATIONFacts
1. The Antecedents: The underlying dispute arose from a contract for the construction of the new Ninoy Aquino International Airport (NAIA) Terminal 2 building. A consortium, including Tokyu Construction Co., Ltd. and BF Corporation, was awarded the contract. Disagreements emerged between Tokyu and BF Corporation regarding the allocation of work and fees. BF Corporation filed a complaint against Tokyu for breach of the consortium agreement, seeking damages and injunctive relief. 2. Procedural History: BF Corporation's complaint led to a 72-hour Temporary Restraining Order (TRO) issued by the Executive Judge of the Regional Trial Court of Pasig City. The case was raffled to Branch 71, presided over by respondent Judge Celso D. Laviña. Despite Tokyu's opposition citing Presidential Decree (PD) 1818 and Supreme Court Circulars prohibiting injunctions in government infrastructure projects, the respondent judge extended the TRO. This led to a Petition for Certiorari and Prohibition filed by Tokyu with the Court of Appeals (CA), which issued its own TRO. The CA later allowed the injunction hearing to proceed but limited its scope. Tokyu's subsequent motions for reconsideration and to postpone hearings were denied, and a Writ of Preliminary Prohibitory and Mandatory Injunction was issued. The CA later ruled that some of the respondent judge's orders, including the writ of injunction, were issued with grave abuse of discretion. This CA decision was challenged in a Petition for Review before the Supreme Court, which was still pending. 3. The Petition: This administrative complaint was filed by Attys. Alfredo Benjamin S. Caguioa and Ricardo Ma. P.G. Ongkiko against Judge Celso D. Laviña for grave misconduct. The complainants alleged that the respondent judge maliciously issued several void Orders and a Writ of Preliminary Prohibitory and Mandatory Injunction, specifically those dated January 21, 1997; June 13, 1997; June 30, 1997; July 8, 1997; and July 18, 1997. The core of the petition is that the respondent judge's January 21, 1997 Order, extending the TRO, blatantly disregarded PD 1818 and Supreme Court Circulars Nos. 13-93 and 68-94, which prohibit courts from issuing injunctions that impede government infrastructure projects. The complainants sought administrative sanctions against the respondent judge for this alleged violation.
Issue(s)
Whether the administrative complaint regarding the Orders dated June 13, June 30, and July 8, 1997, and the Writ dated July 18, 1997, is premature. Whether respondent judge committed grave misconduct and conduct prejudicial to the administration of justice by issuing the Order dated January 21, 1997, extending the TRO despite the prohibition under PD 1818 and relevant Supreme Court Circulars.
Ruling
The Supreme Court found respondent judge guilty of grave misconduct and conduct prejudicial to the administration of justice for his violation of PD 1818 and Supreme Court Administrative Circular Nos. 13-93 and 68-94. He was fined ₱5,000. The complaint regarding the other Orders was dismissed for being premature. The Court warned that a repetition of the offense would be dealt with more severely.
Ratio Decidendi
On the issue of prematurity regarding the Orders dated June 13, June 30, and July 8, 1997, and the Writ dated July 18, 1997: The Court held that these matters should be threshed out in the pending appeal (G.R. No. 131155) before ruling on them in the administrative case. Disciplinary proceedings against judges do not complement or substitute judicial remedies. An inquiry into a judge's liability should only be made after available judicial remedies have been exhausted and decided with finality. Resorting to administrative disciplinary action before judicial remedies are settled constitutes an abuse of court processes. The correctness of the judge's orders, upon which the viability of the recourse depends, must first be settled through appellate review. Therefore, ruling on these specific orders in the administrative case would be premature. On the issue of respondent judge's administrative liability for the Order dated January 21, 1997: The Court found respondent judge guilty of grave misconduct. The January 21, 1997 Order extended a 72-hour TRO to a full 20-day period, despite the clear prohibition under PD 1818 and Supreme Court Circulars Nos. 13-93 and 68-94, which prohibit courts from issuing injunctions that would delay government infrastructure projects. The Court emphasized that PD 1818 clearly and categorically deprives courts of jurisdiction to issue such writs. The fact that Tokyu's verified Opposition brought PD 1818 and the Circulars to the judge's attention made his subsequent issuance of the order even more egregious. The judge's assertion that the order did not prohibit any person from proceeding with the project was contradicted by the directives in the TRO itself, which enjoined Tokyu from receiving compensation and engaging subcontractors, and MIAA from paying Tokyu, thereby interfering with the project's execution. The Court found the judge's explanation to be a contrived subterfuge to evade liability, demonstrating either feigned misunderstanding or contumacious indifference to the law. His disregard of the clear mandate of PD 1818 and the Supreme Court Circulars constitutes grave misconduct and conduct prejudicial to the administration of justice.
Main Doctrine
A judge's blatant disregard of clear statutory provisions, such as Presidential Decree No. 1818 which prohibits the issuance of injunctive writs in cases involving government infrastructure projects, constitutes grave misconduct and conduct prejudicial to the administration of justice, notwithstanding the presumption of regularity and good faith in the performance of judicial functions. Administrative liability may subsist even if the questioned order can no longer be reversed or its effects abjured.