A.M. No. RTJ-06-2001 August 16, 2006
Equitable PCI Bank, Inc. vs. Judge Celso D. Laviña

FACTS

This administrative case arose from Civil Case No. 70098, a suit for specific performance and injunction filed by Camden Industries, Inc. against Equitable PCI Bank. Complainant bank charged respondent Judge Celso D. Laviña with gross misconduct, ignorance of the law, and rendering an unjust order, alleging visible bias for Camden. The judge issued a preliminary injunction against the bank after a hearing. During pre-trial, the bank moved to refer the case to mediation, but Camden opposed, citing irreconcilable positions and a pending criminal case. Respondent judge, finding settlement impossible, proceeded with the pre-trial.
Subsequently, the bank filed a petition for certiorari with the Court of Appeals challenging the injunction and the denial of mediation. Shortly before a scheduled hearing for Camden’s evidence, bank counsel filed a motion to defer proceedings, which was not set for hearing. With no temporary restraining order from the appellate court, respondent judge denied the motion in open court. Bank counsel then manifested the bank would no longer participate and left the courtroom despite a judge’s order to locate him. Respondent judge then allowed Camden’s witness to testify and, applying the One-Day Examination of Witness Rule, declared the bank to have waived cross-examination.

ISSUE

Whether respondent judge is administratively liable for gross ignorance of the law or procedure and for bias in handling Civil Case No. 70098.

RULING

The Supreme Court DISMISSED the complaint for lack of merit. The Court found no evidence of gross ignorance, bias, or unjust judgment. A judge’s actions, even if erroneous, are not necessarily administratively liable unless done in bad faith, fraud, or with deliberate intent to cause an injustice. The respondent’s orders were within his judicial discretion. His denial of the motion to defer was proper absent a restraining order from a higher court. The application of the One-Day Examination of Witness Rule after the bank’s counsel voluntarily absented himself was a reasonable exercise of discretion to prevent undue delay. The subsequent dismissal by the Court of Appeals of the bank’s certiorari petition challenging these same orders indicated a lack of grave abuse of discretion. The bank’s remedy against perceived erroneous interlocutory orders was judicial appeal, not an administrative complaint. The allegations of bias were unsubstantiated, as the assailed actions were judicial in nature and the judge’s efforts to manage the case calendar and prevent delay were not improper.