G.R. No. RTJ-07-2044; June 22, 2011
ATTY. FACUNDO T. BAUTISTA, Complainant, vs. JUDGE BLAS O. CAUSAPIN, JR., Presiding Judge, Regional Trial Court, Branch 32, Guimba, Nueva Ecija, Respondent.

FACTS

Complainant Atty. Facundo T. Bautista filed an administrative complaint against respondent Judge Blas O. Causapin, Jr. for gross ignorance of the law and gross misconduct. The complaint stemmed from the judge’s handling of Civil Case No. 1387-G, a complaint for partition filed by Atty. Bautista’s clients. The respondent judge granted three successive motions for extension of time to file an answer filed by the defendants, despite the motions lacking a notice of hearing. Subsequently, the plaintiffs filed a motion to declare the defendants in default. After several hearings, the respondent judge, in a Resolution dated September 18, 2006, dismissed the complaint without prejudice. He cited two grounds: (1) the verification and certification on non-forum shopping attached to the complaint was not signed by two of the plaintiffs, violating Rule 7, Section 5 of the Rules of Court, and (2) compulsory parties (the heirs of Baudelio T. Bautista and Aurora T. Bautista) were not properly named in the complaint, violating Rule 3, Sections 2, 3, and 7. The judge held the defendants could not be declared in default for failing to answer a defective complaint. Atty. Bautista alleged the judge exhibited gross ignorance in granting the defective motions and in dismissing the complaint motu proprio without a hearing on the dismissal. He also questioned the judge’s impartiality, alleging the judge had a drinking spree with one defendant and both were Masons, and accused the judge of gross misconduct for allegedly asking him to withdraw the motion to declare the defendants in default.

ISSUE

Whether respondent Judge Blas O. Causapin, Jr. is administratively liable for gross ignorance of the law and gross misconduct based on his actions in Civil Case No. 1387-G.

RULING

The Supreme Court found respondent Judge Blas O. Causapin, Jr. GUILTY of gross ignorance of the law and was FINED in the amount of Twenty Thousand Pesos (P20,000.00). The Court held that the judge committed gross ignorance of the law in two instances. First, by granting the defendants’ motions for extension of time which were not set for hearing and were therefore mere scraps of paper, he displayed a lack of familiarity with basic procedural rules. Second, his motu proprio dismissal of the complaint for defective verification and certification on non-forum shopping was a blatant disregard of Rule 7, Section 5, which explicitly requires such dismissal to be “upon motion and after hearing.” The judge’s act of dismissing the case without a motion from a party and without conducting a hearing specifically for that purpose constituted gross ignorance. The Court clarified that the defect in the verification/certification was curable, and the appropriate remedy was to order its correction, not outright dismissal. The charge of gross misconduct for alleged partiality and ex parte communication was not substantiated by clear and convincing evidence. However, his grossly ignorant actions warranted administrative sanction.