G.R. No. RTJ-07-2050, June 27, 2007
Spouses Arleen and Lorna Oliveros, complainants, vs. Honorable Dionisio C. Sison, Acting Presiding Judge, Regional Trial Court, Branch 74, Antipolo City, respondent.

FACTS

Complainants filed a case for Declaration of Nullity of Deed with Damages and Injunction against spouses John and Susana Mallett concerning a parcel of land. Respondent Judge Sison initially denied the complainants’ prayer for a Temporary Restraining Order (TRO) and preliminary injunction, finding no clear right to protect. Subsequently, the defendants filed a motion for a TRO and preliminary injunction against the complainants to prevent them from occupying the property, which the judge granted. Complainants filed a motion for reconsideration and a motion for voluntary inhibition, alleging bias after observing the defendant’s relative exiting the judge’s chambers. Both motions were denied.
After the issuance of a writ of injunction against them, defendants filed a “Motion to Cite Plaintiffs in Contempt,” alleging the complainants violated the injunction order. Complainants claim they did not receive a copy of this motion. Without requiring a separate petition or docket fee, and despite the complainants’ absence at the hearing, Judge Sison deemed the matter submitted. On the same day as the hearing, he issued an order finding the complainants guilty of indirect contempt and ordering their imprisonment for six months, along with the immediate issuance of a warrant of arrest.

ISSUE

Whether respondent Judge Sison is administratively liable for Gross Ignorance of the Law for his handling of the indirect contempt proceedings.

RULING

Yes, the Supreme Court found Judge Sison guilty of Gross Ignorance of the Law. The legal logic centers on a clear violation of the mandatory procedure for indirect contempt under Section 4, Rule 71 of the Rules of Court. The rule explicitly requires that a charge for indirect contempt committed against a court or officer must be initiated by a verified petition or a formal written charge, filed as a separate, independent action with corresponding docket fees. The defendants’ mere “Motion to Cite Plaintiffs in Contempt” was a procedurally infirm pleading that did not comply with these mandatory requirements. By entertaining this motion, setting it for hearing, and issuing a contempt order and arrest warrant based on it, Judge Sison demonstrated a fundamental disregard for established rules.
The Court rejected his justification that requiring a separate petition would “favor multiplicity of suits,” deeming it a lame excuse for violating clear procedural mandates. Furthermore, the undue haste in issuing the contempt order on the very day of the hearing, without ensuring the complainants received proper notice and an opportunity to be heard, compounded the error and deprived them of a fundamental right. These actions, taken together, constituted gross ignorance of the law, as they were not mere errors of judgment but a patent misapplication of basic, elementary rules. The presumption of good faith was overcome. Accordingly, the Court imposed a fine of Ten Thousand Pesos (P10,000.00) on Judge Sison.