G.R. No. RTJ-07-2075 October 9, 2007
Atty. Ubaldino A. Lacurom vs. Judge Juanita C. Tienzo, RTC, Branch 27, Cabanatuan City

FACTS

Complainant Atty. Ubaldino Lacurom charged respondent Judge Juanita Tienzo with Gross Ignorance of the Law. The first charge concerned Civil Case No. 4971, a replevin suit. Complainant alleged the judge erroneously issued the writ despite the plaintiff’s failure to prove ownership and entitlement to possession of the subject vehicle, which had been sold and conveyed to third parties. He further accused the judge of unduly delaying the property’s release by granting plaintiffs an extension to post the indemnity bond, thereby exceeding the five-day period under the Rules, and subsequently issuing an order that delivered the vehicle to plaintiffs while setting aside the bond requirement.
The second charge pertained to Civil Case No. 4884, an appealed unlawful detainer case. Complainant alleged the judge rendered a decision that violated the constitutional mandate to state clearly and distinctly the facts and the law. He also criticized an order as poorly written and unbecoming of an RTC judge. However, complainant admitted this second charge was included at the behest of a retired colleague. Respondent judge sought dismissal, arguing complainant lacked legal personality and locus standi, and that any errors were judicial in nature, correctible by appeal, not administrative sanction.

ISSUE

Whether respondent Judge Juanita Tienzo is administratively liable for Gross Ignorance of the Law based on the alleged errors in the replevin case and the appealed unlawful detainer decision.

RULING

The Court found respondent judge administratively liable only for the second charge concerning the deficient decision. On the first charge, the alleged errors in the replevin case involved the exercise of judicial discretion and interpretation of procedural rules. Such errors, absent proof of bad faith, malice, or corruption, are not correctible through an administrative proceeding. The proper remedy for an aggrieved party is a judicial appeal or a petition for certiorari. Therefore, this charge lacks merit.
Regarding the second charge, the Court held respondent judge liable for Gross Ignorance of the Law. The Constitution mandates that no decision shall be rendered without expressing clearly and distinctly the facts and the law on which it is based. The judge’s decision in the unlawful detainer case was a mere “minute decision” that adopted the findings of the lower court by reference without an independent, clear statement of facts and law. While memorandum decisions are permitted under specific conditions, such as when a case is in line with applicable precedents, the judge failed to comply with the stringent requirements for their validity. Her reliance on the Francisco v. Permskul precedent was misplaced, as the factual circumstances justifying a memorandum decision were not present. This failure constituted a blatant disregard of a basic and well-known constitutional rule, amounting to gross ignorance of the law. The Court imposed a fine of Twenty Thousand Pesos (P20,000.00) with a stern warning.