G.R. No. RTJ-09-2182. September 5, 2012
GOVERNMENT SERVICE INSURANCE SYSTEM, represented by ATTY. LUCIO L. YU, JR., Complainant, vs. EXECUTIVE JUDGE MARIA A. CANCINO-ERUM and JUDGE CARLOS A. VALENZUELA, Respondents.

FACTS

This administrative case originated from a civil action filed by Belinda Martizano seeking to restrain the implementation of a Department Order affecting compulsory third-party liability insurance. The case, docketed as Civil Case No. MC08-3660, was filed in the Regional Trial Court (RTC) of Mandaluyong City. On July 21, 2008, the case was assigned to Branch 213, presided by Judge Carlos A. Valenzuela. The Government Service Insurance System (GSIS), a defendant in the civil case, subsequently charged Executive Judge Maria A. Cancino-Erum and Judge Valenzuela with grave misconduct, gross ignorance of the law, and violation of the Rules of Court.
GSIS alleged that Judge Erum, as Executive Judge, violated Section 2, Rule 20 of the Rules of Court by assigning the case to Branch 213 without a proper raffle. GSIS claimed that during the scheduled raffle, Judge Erum announced an automatic assignment to Branch 213 based on a local “rotation scheme” practice for injunction cases, rather than conducting a random draw using the roulette. GSIS also charged Judge Valenzuela with manifest partiality for consenting to this assignment and for issuing a temporary restraining order in the case without requiring a bond, despite his alleged prior connection with an entity opposed to the challenged Department Order.

ISSUE

Whether respondents Executive Judge Maria A. Cancino-Erum and Judge Carlos A. Valenzuela are administratively liable for violating raffle procedures and for alleged partiality in handling Civil Case No. MC08-3660.

RULING

The Supreme Court granted the respondents’ motions for reconsideration, set aside its prior resolution imposing fines, and dismissed the administrative charges. The Court found that the assignment of the case, while deviating from the strict use of a roulette, was not a malicious violation of raffle rules. The practice described by Judge Erum—where branches were excluded from subsequent raffles for injunction cases until all eligible branches had received one—was intended to ensure an equitable distribution of such sensitive cases. The Court noted this was a bona fide, though technically imperfect, attempt at fairness, not an act of corruption or gross ignorance.
Regarding Judge Valenzuela, the Court held that the charges of partiality were unsubstantiated. His prior employment with an insurance company did not automatically constitute a conflict of interest requiring inhibition, and his judicial actions in issuing the TRO and denying the motion to dismiss were within his adjudicatory discretion. The Court emphasized that errors in judgment, if any, are not correctible through administrative proceedings but through appropriate judicial remedies like appeal or certiorari, which GSIS did not adequately pursue. The administrative complaint was thus an improper substitute for these available appellate recourses. The Court reminded all raffle committees to strictly adhere to established procedures.