AM RTJ 04 1853; (June, 2004) (Digest)
G.R. No. RTJ-04-1853. June 8, 2004.
GOV. JOSEFINA M. DELA CRUZ, Complainant, vs. JUDGE VICTORIA VILLALON-PORNILLOS, Respondent.
FACTS
The Provincial Government of Bulacan secured a favorable final judgment in an unlawful detainer case against Atty. Francisco Galman-Cruz. The Municipal Trial Court (MTC) decision was affirmed by the Regional Trial Court (RTC) and the Court of Appeals, and the Supreme Court denied Galman-Cruz’s petition. The judgment became final and executory in November 2000. Following the issuance of a writ of execution and a special writ of demolition by the MTC, Galman-Cruz filed a petition for certiorari with the RTC, which was raffled to Branch 10 presided by respondent Judge Victoria Villalon-Pornillos. Respondent judge issued a 72-hour Temporary Restraining Order (TRO) on November 7, 2002, and later a preliminary injunction, halting the demolition.
ISSUE
Whether respondent judge is administratively liable for Gross Ignorance of the Law for issuing a TRO and preliminary injunction against the enforcement of a final and executory judgment.
RULING
Yes, respondent judge is guilty of Gross Ignorance of the Law. The Supreme Court emphasized that a final and executory judgment is immutable and unalterable. Issuing an injunction to restrain its execution is a patent nullity, as the issuing court would be acting without jurisdiction or with grave abuse of discretion. The Court found that respondent judge disregarded this fundamental principle and the specific prohibition under Section 5, Rule 58 of the Rules of Court, which bars injunctive relief when it would dispose of the case without a full trial on the merits or affect a judgment already rendered. Her defense—that she acted to prevent an allegedly illegal demolition based on unresolved issues—constituted a blatant disregard of the finality of the adjudicated case. The Court held that such actions demonstrated not mere error of judgment but a gross, inexcusable, and conscious ignorance of basic, settled legal doctrines. Consequently, respondent judge was fined P20,000.00 with a stern warning.