A.M. No. RTJ-08-2133 ; August 6, 2008
Datu Omar S. Sinsuat and Mariano H. Paps, complainants, vs. Judge Vicente A. Hidalgo, Regional Trial Court, Branch 37, Manila, respondent.

FACTS

Complainants, as counsel for defendants in Civil Case No. 03106921, initiated this administrative case against Judge Vicente A. Hidalgo. They alleged that the judge issued a Temporary Restraining Order and a writ of preliminary injunction against the Philippine National Oil Company-Energy Development Corporation (PNOC-EDC), enjoining a bidding for wooden poles under the government’s “O-Ilaw” rural electrification project. Complainants contended this act constituted gross ignorance of the law, as it blatantly violated the explicit prohibitions under Presidential Decree No. 1818 and Republic Act No. 8975 , as well as relevant Supreme Court Administrative Circulars, against issuing injunctive reliefs on government infrastructure projects. They further cited instances of alleged bias, including declaring their clients in default and disqualifying their counsel.
The procedural history involved multiple exchanges of letters and motions between complainants and the Office of the Court Administrator (OCA) starting in 2003. The OCA initially declined to give the complaint due course for non-compliance with the verification requirement under Rule 140 of the Rules of Court. Meanwhile, the Court of Appeals, in a related petition for certiorari, annulled the judge’s orders, finding a grave abuse of discretion in issuing the injunction in violation of the law. Judge Hidalgo, who had compulsorily retired in July 2006, later argued for dismissal, claiming the Court lost administrative jurisdiction upon his retirement and that he was denied due process as the charges were never formally docketed.

ISSUE

The primary issues were: (1) whether the complaint could be given due course despite procedural deficiencies; (2) whether proceeding would violate respondent’s right to due process; and (3) whether respondent was administratively liable for gross ignorance of the law.

RULING

The Supreme Court found Judge Hidalgo administratively liable for gross ignorance of the law. On procedural matters, the Court held that the series of letters and motions from complainants, though unverified, substantially alleged administrative offenses and were sufficient to initiate the case. The OCA’s own actions in requiring comments from the judge confirmed that an administrative matter was pending. The Court retained jurisdiction as the alleged infractions occurred during his active service, and retirement did not absolve him from liability for acts committed prior thereto.
On the merits, the Court ruled that the judge’s issuance of the injunction was a clear, gross, and inexcusable violation of a settled legal prohibition. PD 1818 and RA 8975 establish a direct and categorical ban against courts from issuing restraining orders or injunctions against government infrastructure projects. The “O-Ilaw” project, being a critical rural electrification program, unquestionably falls under this protected category. The law’s mandate is simple and unequivocal; thus, the judge’s act demonstrated a fundamental lack of familiarity with basic legal principles. His failure to apply such a well-known prohibition constituted gross ignorance of the law, which is a serious charge. Considering his recent previous administrative sanction for a similar offense, the Court imposed a fine of Forty Thousand Pesos (P40,000), to be deducted from his retirement benefits.