G.R. No. RTJ-99-1510. November 6, 2000.
COMMISSIONER RUFUS B. RODRIGUEZ, complainant, vs. JUDGE RODOLFO R. BONIFACIO, RTC, Branch 151, Pasig City, respondent.

FACTS

The National Bureau of Investigation, in coordination with other agencies, apprehended twenty Chinese nationals, including Ma Jing, for allegedly working without permits. They were detained at the Bureau of Immigration (BI) Detention Center. Ma Jing filed a petition for habeas corpus before respondent Judge Rodolfo R. Bonifacio, alleging unlawful detention without formal charges. The judge issued the writ. The BI, in its return, stated that a charge sheet for violation of immigration laws had been filed against Ma Jing and that she had manifested an intent to apply for voluntary deportation.
Despite the BI’s return showing a pending administrative charge, Judge Bonifacio, in an Order dated May 27, 1999, granted the petition. He ruled that Ma Jing had valid travel documents, that the charge sheet was a mere accusation, and that her detention was unlawful due to the absence of a formal commitment order from the Immigration Commissioner. Subsequently, the judge also found Commissioner Rufus B. Rodriguez guilty of indirect contempt for his public criticisms of the habeas corpus ruling.

ISSUE

Whether respondent Judge Rodolfo R. Bonifacio is administratively liable for Gross Ignorance of the Law and Grave Misconduct in relation to his handling of the habeas corpus petition and the contempt proceedings.

RULING

Yes, the Supreme Court found respondent judge administratively liable for Gross Ignorance of the Law. The legal logic is clear and multi-faceted. First, on the habeas corpus ruling, the judge displayed a fundamental misunderstanding of the writ’s purpose and the jurisdiction of the Bureau of Immigration. Habeas corpus is not available to challenge a detention by virtue of a valid order of deportation or a pending charge before the BI, which exercises quasi-judicial powers. The BI’s return, indicating a filed charge sheet, rendered the petition moot. By ordering Ma Jing’s release, the judge unjustifiably interfered with the BI’s lawful exercise of its exclusive jurisdiction over deportation cases.
Second, the judge’s contempt order against Commissioner Rodriguez was issued with grave abuse of discretion. The alleged contemptuous statements were made publicly outside the courtroom and did not constitute direct contempt. For indirect contempt, proper procedural requirements, such as a charge in writing and an opportunity to comment, were blatantly disregarded. The judge’s immediate imposition of a fine and threat of imprisonment without due process was a patent violation of basic procedural rules.
The totality of these actions demonstrated not mere error but gross ignorance of settled legal principles on habeas corpus, immigration jurisdiction, and contempt procedures. Such incompetence and failure to maintain professional competence, as required by the Code of Judicial Conduct, eroded public confidence in the judiciary. Consequently, the Court imposed the penalty of dismissal from service with forfeiture of all benefits, except accrued leave credits, and with prejudice to re-employment in any government branch.