A.M. No. RTJ-10-2216, June 26, 2012
State Prosecutors II Josef Albert T. Comilang and Ma. Victoria Suñega-Lagman, Complainants, vs. Judge Medel Arnaldo B. Belen, Regional Trial Court, Branch 36, Calamba City, Respondent.

FACTS

State Prosecutor Comilang, assisting the Calamba City Prosecutor’s Office, moved to defer hearings before respondent Judge Belen due to a conflicting preliminary investigation schedule. Instead of granting the motion, Judge Belen fined Comilang and required him to explain. Comilang filed motions for reconsideration, which Judge Belen treated as contemptuous, ultimately finding him liable for contempt and imposing a ₱20,000 fine. Comilang petitioned the Court of Appeals (CA), which issued a Temporary Restraining Order (TRO) and later a writ of preliminary injunction, enjoining Judge Belen from enforcing his contempt orders.
Despite the CA’s injunctive writ, Judge Belen proceeded to issue show-cause orders, subpoenas, and a subsequent contempt citation against Comilang for non-compliance with the earlier voided orders. The complainants alleged these acts constituted harassment, noting that Comilang was prosecuting a libel case against Judge Belen. A supplemental complaint detailed similar harassment against another prosecutor involved in the same libel case.

ISSUE

Whether respondent Judge Belen is administratively liable for his actions in issuing contempt citations and related orders in defiance of a Court of Appeals injunction.

RULING

Yes, Judge Belen is administratively liable. The Supreme Court found him guilty of Grave Abuse of Authority and Gross Ignorance of the Law. The legal logic is clear: once the CA issued a TRO and preliminary injunction, Judge Belen was mandated to desist from any action enforcing or related to the enjoined orders. His continued issuance of show-cause orders, subpoenas, and a new contempt citation for non-compliance with the stayed judgment was a blatant defiance of a superior court’s lawful order. This constitutes gross ignorance, as a judge is duty-bound to know that an injunctive writ deprives the court of jurisdiction to proceed on the matter enjoined. His actions demonstrated not merely error but a willful disregard of basic legal principles and procedural rules. The Court emphasized that such conduct, compounded by his being a repeat offender in administrative cases, erodes public confidence in the judiciary. Consequently, the penalty of dismissal from service with forfeiture of benefits and disqualification from reemployment was imposed.