A.M. No. RTJ-07-2058; April 7, 2009
Dolores S. Bago, Complainant, vs. Judge Ernesto P. Pagayatan, Regional Trial Court, Branch 46, San Jose, Occidental Mindoro, Respondent.

FACTS

Complainant Dolores S. Bago filed an administrative complaint against Judge Ernesto P. Pagayatan for Grave Abuse of Discretion, Misconduct, Inefficiency, and Gross Ignorance of the Law concerning Criminal Case No. R-4295 for Murder. The case stemmed from the killing of Mayor Guillermo Salas in 1995. After a series of reinvestigations and resolutions by the prosecution and the Department of Justice, the Office of the President, through the Executive Secretary, ordered the inclusion of certain accused in the information. The case was transferred to Judge Pagayatan’s court. After the trial was concluded and the parties had submitted their memoranda, the prosecution filed a “Motion to Admit Third Amended Information” to drop several accused, based on a new resolution from the Executive Secretary. Judge Pagayatan issued an Order on January 27, 2000, admitting the Third Amended Information and ordering the withdrawal of charges against three accused. This Order was challenged via a Petition for Certiorari and Prohibition before the Court of Appeals, which granted the petition, set aside Judge Pagayatan’s Order, and found that he committed grave abuse of discretion. Judge Pagayatan later inhibited himself from the case, which was eventually decided by another judge. In his defense, Judge Pagayatan claimed he acted without bad faith, malice, or corrupt motive, and that any error was merely procedural.

ISSUE

Whether Judge Ernesto P. Pagayatan is administratively liable for Gross Ignorance of the Law for issuing the Order dated January 27, 2000, which admitted the Third Amended Information and withdrew charges against several accused after the case had been submitted for resolution.

RULING

Yes, Judge Pagayatan is administratively liable for Gross Ignorance of the Law. The Supreme Court agreed with the recommendation of the Office of the Court Administrator (OCA). The Court found that Judge Pagayatan’s act of admitting the amended information after the case had been submitted for decision constituted gross ignorance of the law and procedure. The ruling in Crespo v. Mogul establishes that once a case is filed in court, any disposition rests in the sound discretion of the court, and the prosecution cannot impose its judgment. By allowing the amendment based solely on the prosecution’s new resolution, Judge Pagayatan disregarded this established doctrine. His error was not a simple judicial error but a gross misapplication of basic rules, warranting administrative sanction. The Court imposed a fine of Twenty Thousand Pesos (₱20,000.00) with a stern warning.