G.R. No. RTJ-09-2190. April 23, 2010.
Hadja Sohurah Dipatuan, Complainant, vs. Judge Mamindiara P. Mangotara, Respondent.

FACTS

Complainant Hadja Sohurah Dipatuan filed an administrative complaint against respondent Judge Mamindiara P. Mangotara for Gross Ignorance of the Law and Grave Abuse of Authority. The case stemmed from the judge’s actions in Criminal Case No. 3620-01 for murder, where complainant’s husband was an accused. Respondent, previously designated as Acting Presiding Judge of the RTC of Marawi City, Branch 10, rendered a Decision on December 28, 2007, convicting the accused and increasing their bail. This was despite the Supreme Court having revoked his designation and appointed a new judge on December 26, 2007.
Complainant alleged bias, claiming respondent was related to the victim, and grave abuse of authority for deciding the case after his authority had been revoked. Respondent countered that he decided the long-pending case promptly, received notice of the new designation only later, and promptly recalled his subsequent orders upon realizing a procedural error concerning bail.

ISSUE

Whether respondent Judge Mamindiara P. Mangotara is administratively liable for Gross Ignorance of the Law and Grave Abuse of Authority.

RULING

The Supreme Court found respondent guilty of Gross Ignorance of the Law but not of Grave Abuse of Authority regarding bias. On the charge of bias and partiality, the Court ruled that complainant failed to substantiate the claim of relationship within the prohibited degree under Rule 137 of the Rules of Court. Inhibition was thus discretionary, and his choice not to inhibit, absent proof of relationship, was not an abuse of authority.
However, the Court found respondent liable for Gross Ignorance of the Law for issuing the Decision and Orders after his designation had been revoked. The Supreme Court’s Resolution dated December 26, 2007, which designated a new judge, immediately stripped him of authority over the case. His subsequent acts were void for lack of jurisdiction. Furthermore, his act of increasing the bail bond after rendering a judgment of conviction, instead of ordering its cancellation, constituted a patent disregard of established rules that after a conviction, bail is no longer a matter of right and the court should order the accused’s commitment. Such a gross and patent error implies bad faith and constitutes gross ignorance of basic legal principles.
Considering it was his first infraction in 13 years of service, his admission of mistake, and his prompt corrective action, the Court imposed a fine of Twenty Thousand Pesos (₱20,000.00) to be deducted from his retirement benefits.