Cabili vs. Balindong

A judge commits gross ignorance of the law by issuing a temporary restraining order or injunction that interferes with the execution of a final judgment by a co-equal court, even if the judge subsequently dismisses the case for lack of jurisdiction, because the doctrine of judicial stability strictly prohibits courts of concurrent jurisdiction from interfering with each other's orders or processes.

A civil action for damages was filed against Mindanao State University (MSU) and others in the Regional Trial Court (RTC) of Iligan City, Branch 6, arising from a vehicular accident. The Iligan City RTC rendered a decision holding MSU liable for damages, which the Court of Appeals affirmed and eventually lapsed into finality on January 19, 2009. Following the entry of judgment, the Iligan City RTC issued a writ of execution. MSU failed to comply with the writ, prompting Sheriff Gerard Peter Gaje to serve a Notice of Garnishment on MSU’s depository bank, the Land Bank of the Philippines (LBP), Marawi City Branch. The Office of the Solicitor General belatedly opposed the execution, but the Iligan City RTC denied the opposition.

• Civil Case No. 06-2954 and Final Judgment: An action for damages was filed against MSU in the Iligan City RTC, Branch 6, arising from a vehicular accident. The court rendered a decision holding MSU liable for ₱2,726,189.90. The Court of Appeals affirmed the decision, which lapsed into finality on January 19, 2009.
• Writ of Execution and Garnishment: On March 10, 2009, the Iligan City RTC issued a writ of execution. MSU failed to comply, prompting Sheriff Gerard Peter Gaje to serve a Notice of Garnishment on MSU’s account with the Land Bank of the Philippines (LBP), Marawi City Branch, on March 24, 2009. The Office of the Solicitor General belatedly opposed the execution, but the Iligan City RTC denied the opposition on March 31, 2009.
• Petition for Prohibition and TRO Issuance: On April 1, 2009, MSU filed a petition for prohibition and mandamus with an application for a TRO and/or preliminary injunction in the Marawi City RTC, Branch 8, which was presided over by respondent Judge Rasad G. Balindong. The petition sought to enjoin LBP and Sheriff Gaje from proceeding with the garnishment. After a hearing on April 8, 2009, the respondent Judge issued a TRO restraining Sheriff Gaje from garnishing the MSU funds.
• Subsequent Dismissal and Administrative Complaint: On April 21, 2009, Sheriff Gaje moved to dismiss the case for lack of jurisdiction. The respondent Judge granted the motion and dismissed the petition. Complainant Atty. Tomas Ong Cabili, counsel for the private plaintiffs in the Iligan City RTC case, subsequently filed an administrative complaint against the respondent Judge for interfering with the order of a co-equal court.

• Gross Ignorance of the Law: Petitioner argued that the respondent Judge displayed gross ignorance of the law, grave abuse of authority, and grave misconduct by interfering with the orders of a co-equal court (Iligan City RTC, Branch 6) when the respondent Judge issued a TRO to enjoin Sheriff Gaje from garnishing MSU’s funds.

• No Interference: Respondent Judge denied interfering with the order of a co-equal court, claiming he merely gave the parties the opportunity to be heard and eventually dismissed the petition for lack of jurisdiction.
• Good Faith: Complainant himself later manifested that the respondent Judge is "basically a good Judge" and that an admonition would suffice, implying the absence of malice or deliberate intent to circumvent the law.

• Gross Ignorance of the Law: Whether the respondent Judge is guilty of gross ignorance of the law for issuing a TRO that restrained the enforcement of a writ of execution issued by a co-equal court.
• Exculpation by Subsequent Dismissal: Whether the respondent Judge's subsequent dismissal of the petition for lack of jurisdiction absolves him of administrative liability for the initial issuance of the TRO.
• Effect of Complainant's Manifestation: Whether the complainant's manifestation that the respondent Judge is "basically a good Judge" affects the latter's administrative liability.

• Gross Ignorance of the Law: Respondent Judge was found guilty of gross ignorance of the law for violating the doctrine of judicial stability. The issuance of a TRO to restrain the enforcement of a writ of execution issued by a co-equal court constitutes prohibited interference. A court that acquires jurisdiction over a case retains exclusive jurisdiction over its judgment and execution, including all incidents arising thereof. Splitting jurisdiction by allowing a co-equal court to interfere with execution proceedings is obnoxious to the orderly administration of justice. The proper recourse for an aggrieved party is to seek relief from the issuing court or elevate the matter to a higher court via a petition for certiorari, not to seek a TRO from a co-equal court.
• Exculpation by Subsequent Dismissal: The subsequent dismissal of the petition for lack of jurisdiction did not exculpate the respondent Judge. The initial issuance of the TRO already undermined public confidence in the judiciary by impressing upon the public that the official acts of a co-equal court can be temporarily thwarted. Lack of familiarity with the basic rule of non-interference constitutes gross ignorance of the law.
• Effect of Complainant's Manifestation: The complainant's manifestation regarding the respondent Judge's character and his request for a mere admonition did not affect the outcome. Administrative liability and the commensurate penalty depend on the facts proved and the applicable law and jurisprudence, not on the complainant's personal opinion or change of heart.

• Doctrine of Judicial Stability (Non-Interference) — No court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having the power to grant the relief sought by the injunction. A court that renders judgment has jurisdiction over its judgment to the exclusion of all other coordinate courts, including the power to control its execution and the conduct of its ministerial officers. The Court applied this doctrine to hold the respondent Judge liable, emphasizing that a TRO enjoining the enforceability of a writ addresses the writ itself and not merely the executing sheriff, whose duty is ministerial.
• Gross Ignorance of the Law — When the law is sufficiently basic, a judge owes it to the office to know and simply apply it; anything less constitutes gross ignorance of the law. The Court applied this principle to penalize the respondent Judge, noting that the rule against interfering with co-equal courts is an elementary principle in the administration of justice.

• "no court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having the power to grant the relief sought by the injunction."
• "A court which issued a writ of execution has the inherent power, for the advancement of justice, to correct errors of its ministerial officers and to control its own processes. To hold otherwise would be to divide the jurisdiction of the appropriate forum in the resolution of incidents arising in execution proceedings. Splitting of jurisdiction is obnoxious to the orderly administration of justice."
• "It is not a viable legal position to claim that a TRO against a writ of execution is issued against an erring sheriff, not against the issuing Judge. A TRO enjoining the enforceability of a writ addresses the writ itself, not merely the executing sheriff."
• "When the law is sufficiently basic, a judge owes it to his office to know and to simply apply it. Anything less would be constitutive of gross ignorance of the law."

• Aquino, Sr. v. Valenciano — Followed. The Court cited this case to reinforce that a judge commits grave abuse of discretion for issuing a TRO that interfered with or frustrated the implementation of an order of another court of co-equal jurisdiction.
• Coronado v. Rojas — Followed. The Court relied on this case where a judge was found liable for gross ignorance of the law for enjoining the final and executory decision of the HLURB, a co-equal body, on the pretext that the injunction was directed only at the manner of execution.
• Heirs of Simeon Piedad v. Estrera — Followed. The Court cited this case to emphasize that judges who act on applications for injunction regarding matters pertaining to a co-equal court act in blatant disregard of the doctrine of judicial stability.
• Benito v. Balindong — Cited. This previous administrative case against the same respondent Judge was noted to establish that the present offense is his second offense, justifying a penalty within the range for serious charges.

• Article VIII, Section 1, paragraph 2, 1987 Constitution — Defines judicial power as including the duty of courts to determine whether there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government. The Court cited this provision to emphasize that the proper remedy against an issuing court that violates the law is to seek redress from a higher court with the authority to nullify the action, not from a co-equal court.
• Rule 65, Rules of Court — Governs petitions for certiorari. The Court identified this as the proper remedy for MSU to challenge the denial of its opposition to the writ of execution, rather than seeking a TRO from a co-equal court.
• Section 16, Rule 39, Rules of Court (Terceria) — Governs proceedings where property levied upon is claimed by a third person other than the judgment obligor or his agent. The Court distinguished this provision, clarifying that it finds no application in this case because the petition for injunction was filed by MSU itself, the judgment obligor, and not a third-party claimant.
• A.M. No. 01-8-10-SC (Amendment to Rule 140) — Classifies gross ignorance of the law as a serious charge punishable by a fine of more than ₱20,000.00 but not exceeding ₱40,000.00, suspension, or dismissal. The Court applied this rule to impose the fine of ₱30,000.00.

Renato C. Corona, Antonio T. Carpio, Presbitero J. Velasco, Jr., Teresita J. Leonardo-De Castro, Diosdado M. Peralta, Lucas P. Bersamin, Jose Portugal Perez, Jose Catral Mendoza.

• Associate Justice Roberto A. Abad — Argued that the respondent Judge did not commit gross ignorance of the law, as the TRO was issued to protect Congress-appropriated funds of a state university from execution that violated COA rules, and was directed at the sheriff's discretion in determining valid assets, not at the co-equal court's judgment. The dissent characterized the issuance of the TRO as, at best, an error of judgment, noting that the judge acted prudently by eventually dismissing the petition for lack of jurisdiction after hearing the parties. The dissent recommended reducing the penalty to ₱20,000.00. Associate Justice Arturo D. Brion and Associate Justice Mariano C. Del Castillo joined this dissent.