A.M. No. RTJ-07-2063, RTJ-07-2064 & RTJ-07-2066 EN BANC; June 26, 2009
Republic of the Philippines, et al. vs. Judge Ramon S. Caguioa, et al.

FACTS

Three consolidated administrative complaints were filed against Judge Ramon S. Caguioa of the RTC of Olongapo City, Branch 74. The first complaint, filed by the Republic through the OSG, stemmed from Civil Case No. 102-0-05, a declaratory relief case filed by Indigo Distribution Corp., et al., importers within the Subic Bay Freeport Zone. The petitioners sought to nullify Section 6 of R.A. No. 9334 , which imposed excise taxes on tobacco and alcohol products even within freeports, and prayed for a TRO and preliminary injunction. Judge Caguioa granted the application for a writ of preliminary injunction, enjoining the implementation of the tax law, finding that the petitioners’ tax exemptions under R.A. No. 7227 constituted a clear legal right.
The second complaint was filed by the Commissioner of Customs, and the third by a private individual, Charles T. Burns, Jr., who alleged irregularities in the judge’s handling of a different case involving a writ of execution. The Office of the Court Administrator consolidated these complaints and recommended that Judge Caguioa be held liable for gross ignorance of the law and conduct prejudicial to the service.

ISSUE

Whether Judge Ramon S. Caguioa is administratively liable for Gross Ignorance of the Law and Conduct Prejudicial to the Best Interest of the Service.

RULING

Yes, Judge Caguioa is guilty as charged. The Supreme Court found his act of issuing a preliminary injunction in the tax case to constitute gross ignorance of the law. The Court emphasized that Section 218 of the National Internal Revenue Code (NIRC) explicitly states that “no court shall have the authority to grant an injunction to restrain the collection of any national internal revenue tax.” This prohibition is categorical and allows for no exception. A judge of his stature is presumed to know this fundamental legal principle. His issuance of the injunction, despite this clear statutory bar, was not a mere error of judgment but a blatant disregard of basic, settled, and elementary rules. Such act eroded public confidence in the courts.
Furthermore, his actions in the other case, where he issued orders without the required proof of service of motions, demonstrated a pattern of disregard for procedural rules. When the law or rule is so elementary, like the injunction ban in tax collection and the requirement for proof of service, failure to know it or acting contrary to it constitutes gross ignorance. This ignorance, coupled with the prejudicial effect on the integrity of the judiciary, warranted the supreme penalty. Accordingly, the Court DISMISSED Judge Ramon S. Caguioa from the service with forfeiture of all retirement benefits, except accrued leave credits. The complaint against Sheriff Christopher T. Perez was dismissed for lack of merit.