Cabili v. Balindong
REITERATIONFacts
The Antecedents: Civil Case No. 06-29542, an action for damages against Mindanao State University (MSU) et al., resulted in a final and executory decision by the Iligan City RTC, affirmed by the Court of Appeals, holding MSU liable for ₱2,726,189.90. Following MSU's failure to comply with the writ of execution issued by the Iligan City RTC, a sheriff served a notice of garnishment on MSU's depository bank, the Land Bank of the Philippines (LBP), Marawi City Branch. Procedural History: In response to the garnishment, MSU filed a petition for prohibition and mandamus with an application for a TRO and/or preliminary injunction against the sheriff and LBP before the RTC, Marawi City, Branch 8, presided over by respondent Judge Rasad G. Balindong. The respondent Judge issued a TRO restraining the sheriff from garnishing the funds and later dismissed MSU's petition for lack of jurisdiction. Complainant Atty. Tomas Ong Cabili filed the instant administrative complaint against the respondent Judge for Gross Ignorance of the Law, Grave Abuse of Authority, Abuse of Discretion, and/or Grave Misconduct, alleging interference with the order of a co-equal court. The Office of the Court Administrator (OCA) found the respondent Judge guilty and recommended a fine, which the Court adopted. The Petition: The administrative complaint, treated as a regular administrative matter, was filed by Atty. Tomas Ong Cabili against Judge Rasad G. Balindong. The core of the complaint is that the respondent Judge, by issuing a TRO to enjoin the execution of a final and executory judgment of a co-equal court (Iligan City RTC), committed gross ignorance of the law and grave abuse of authority. The complainant argued that the respondent Judge interfered with the judicial processes of another branch of concurrent jurisdiction, violating the doctrine of judicial stability. The respondent Judge's subsequent dismissal of the petition for lack of jurisdiction was deemed insufficient to absolve him of liability for his initial actions.
Issue(s)
Whether Judge Balindong is liable for Gross Ignorance of the Law for issuing a Temporary Restraining Order (TRO) against the execution process of a co-equal court.
Ruling
The Supreme Court found Judge Rasad G. Balindong GUILTY of Gross Ignorance of the Law and ordered him to pay a FINE of ₱30,000.00.
Ratio Decidendi
On Issue 1: The Supreme Court held that the doctrine of judicial stability is an elementary principle in the administration of justice. Applying the rule of non-interference, the Court emphasized that no court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction. The Iligan City Regional Trial Court (RTC), having issued the writ of execution, retained exclusive jurisdiction over all incidents of that execution, including the conduct of ministerial officers like the sheriff. The Court noted that a case where an execution order has been issued is considered still pending, and splitting jurisdiction over such proceedings is 'obnoxious to the orderly administration of justice.' Judge Balindong's issuance of a Temporary Restraining Order (TRO) directly frustrated the lawful order of a co-equal body, which he should have known was beyond his authority. The Court further clarified that Rule 39, Section 16 (terceria) did not apply because the petitioner (Mindanao State University (MSU)) was the judgment obligor, not a third-party claimant. Consequently, the Court ruled that when a law is sufficiently basic, a judge's failure to apply it constitutes Gross Ignorance of the Law, regardless of whether the error was subsequently rectified or if the complainant desisted.
Main Doctrine
The doctrine of judicial stability or non-interference dictates that no court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction. A court that acquires jurisdiction over a case and renders judgment therein retains jurisdiction over its judgment, to the exclusion of all other coordinate courts, for its execution and all its incidents. Any challenge to the execution of a judgment must be brought before the issuing court or a higher court, as splitting jurisdiction is considered obnoxious to the orderly administration of justice.