Erice v. Sison
REITERATIONFacts
The Antecedents: Complainant Edgar R. Erice, then Vice Mayor of Caloocan City, filed a complaint against then Mayor Enrico R. Echiverri, et al. before the Office of the Ombudsman for alleged violation of the Government Service Insurance System Act. The Ombudsman issued an Order of Preventive Suspension against Echiverri, et al. for a period not exceeding six (6) months. Procedural History: Echiverri, et al. elevated the matter to the Court of Appeals (CA), which affirmed the Ombudsman's Order of Suspension. Subsequently, Echiverri, et al. filed a Petition for Declaratory Relief with the RTC of Caloocan City, seeking a judicial declaration on the implementation of their suspension. The RTC, initially through Executive Judge Eleanor R. Kwong, issued a 72-hour ex-parte Order enjoining the implementation of the suspension. The case was raffled to Judge Lorenza R. Bordios, who inhibited herself. It was then raffled to respondent Judge Dionisio C. Sison. Despite motions to dismiss and dissolve the TRO, and objections regarding lack of notice to the OSG, Judge Sison proceeded with hearings, denied the OSG's right to cross-examine, extended the TRO, and eventually issued a writ of preliminary injunction. The Petition: Erice filed an administrative complaint against Judge Sison for gross misconduct, knowingly rendering an unjust judgment, and gross ignorance of the law or procedure.
Issue(s)
Whether respondent Judge Sison committed gross ignorance of the law in issuing a TRO and writ of preliminary injunction against the enforcement of the Ombudsman's Order of Suspension, and whether the RTC had jurisdiction to entertain a Petition for Declaratory Relief concerning an order of suspension issued by the Ombudsman, which was already affirmed by the Court of Appeals.
Ruling
The Court finds retired Judge Dionisio C. Sison GUILTY of gross ignorance of the law and orders him to pay a fine of Forty Thousand Pesos (₱40,000.00).
Ratio Decidendi
On the issue of gross ignorance of the law and jurisdiction: The Court held that Judge Sison committed gross ignorance of the law. The RTC had no jurisdiction to interfere with or restrain the execution of the Ombudsman's decisions in disciplinary cases, which are appealable to the CA. This principle is rooted in judicial stability and the doctrine of non-interference among co-equal bodies. Furthermore, court orders or decisions, or those of quasi-judicial bodies, cannot be the subject matter of a petition for declaratory relief, as this is anchored on the principle of res judicata. The RTC's issuance of a TRO and writ of preliminary injunction against the enforcement of the Ombudsman's Order of Suspension, which had already been affirmed by the CA, was a clear violation of these fundamental legal precepts. Judge Sison's actions demonstrated a patent disregard for well-known rules, leading to an inference of bad faith. Even if Section 14 of RA 6770 was later declared ineffective or invalid in subsequent rulings, Judge Sison's failure to adhere to the basic principle of judicial stability and non-interference, especially when the CA had already affirmed the Ombudsman's order, rendered his actions liable for gross ignorance of the law. The OCA's recommendation was affirmed, with a modification in the penalty due to the respondent's retirement.
Main Doctrine
A judge commits gross ignorance of the law when they issue an injunction against the enforcement of an Ombudsman's order of suspension, especially when such order has already been affirmed by the Court of Appeals, violating the principle of judicial stability and non-interference with co-equal bodies.