G.R. No. RTJ-12-2332. June 25, 2014.
EFREN T. UY, NELIA B. LEE, RODOLFO L. MENES and QUINCIANO H. LUI, Complainants, vs. JUDGE ALAN L. FLORES, PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH 7, TUBOD, LANAO DEL NORTE, Respondent.

FACTS

Respondent Judge Alan L. Flores, Presiding Judge of the Regional Trial Court (RTC), Branch 7, Tubod, Lanao del Norte, issued seven orders in a case filed by Mustapha M. Gandarosa. Gandarosa had filed a Rule 65 petition for certiorari and/or prohibition with a prayer for a temporary restraining order (TRO) and preliminary injunction, challenging a Revenue Travel Assignment Order that relieved him as Regional Director of Revenue Region No. 16, Bureau of Internal Revenue (BIR), Cagayan de Oro City, and reassigned him to the BIR Head Office in Quezon City. The orders issued by Judge Flores included: (1) a 72-hour TRO; (2) an extension of the TRO; (3) admission of Gandarosa’s documentary exhibits; (4) a writ of preliminary injunction; (5) an omnibus order treating the comment to the Rule 65 petition (filed via LBC) as a mere scrap of paper; (6) an order requiring the Secretary of Finance and the Commissioner of Internal Revenue to comment on a contempt petition; and (7) an omnibus and interim order impleading additional respondents in the contempt petition and ordering the maintenance of the status quo to retain Gandarosa as Regional Director.
The Court of Appeals (CA), in CA-G.R. SP No. 02753-MIN, annulled all seven orders and directed Judge Flores to dismiss Gandarosa’s petitions, ruling that the RTC lacked jurisdiction because the case involved a personnel action within the exclusive jurisdiction of the Civil Service Commission (CSC). The CA decision became final and executory.
Complainants, Efren T. Uy, Nelia B. Lee, Rodolfo L. Menes, and Quinciano H. Lui, filed an administrative complaint against Judge Flores for gross ignorance of the law, manifest partiality, denial of due process, and conduct prejudicial to the best interest of the service. They alleged that Judge Flores exhibited gross ignorance by assuming jurisdiction over the Rule 65 petition despite the CSC’s exclusive jurisdiction over reassignment issues; issuing a TRO and writ of preliminary injunction effective outside the 12th Judicial Region (where his court is located); and erroneously treating the comment filed via LBC as a mere scrap of paper. They also claimed he violated due process by denying the Secretary of Finance and the Commissioner of Internal Revenue an opportunity to be heard and showed bias in enjoining the implementation of the reassignment orders.
Judge Flores defended himself by citing a prior administrative complaint (A.M. No. 09-1-46-RTC) that was dismissed by the Supreme Court, arguing that the propriety of his orders was a judicial matter and that he acted in good faith. The Office of the Court Administrator (OCA) evaluated the complaint and found Judge Flores guilty of gross ignorance of the law, adopting the CA’s ruling that his orders were void due to lack of jurisdiction and territorial overreach.

ISSUE

Whether Judge Alan L. Flores is administratively liable for gross ignorance of the law, manifest partiality, denial of due process, and conduct prejudicial to the best interest of the service.

RULING

The Supreme Court found Judge Flores liable for gross ignorance of the law but dismissed the charges for manifest partiality, denial of due process, and conduct prejudicial to the best interest of the service.
1. Gross Ignorance of the Law: The Court held that Judge Flores committed gross ignorance of the law by failing to apply basic legal principles and settled jurisprudence. Specifically:
– He assumed jurisdiction over Gandarosa’s Rule 65 petition despite the clear mandate under Section 26(3), Chapter 5, Subtitle A, Book V of the Administrative Code of 1987, which requires employees questioning the validity of a transfer to appeal to the CSC. The Court cited Hon. Vinzons-Chato v. Hon. Natividad and Rualo v. Pitargue, which affirm that such cases fall under CSC jurisdiction and require exhaustion of administrative remedies. Judge Flores’s error was gross and patent, especially since the Office of the Solicitor General had raised the jurisdictional issue in its comment.
– Even assuming the RTC had jurisdiction, Judge Flores violated Section 4, Rule 65 of the Rules of Court, which requires petitions for certiorari to be filed in the RTC exercising jurisdiction over the territorial area where the respondents hold office. The Secretary of Finance and the Commissioner of Internal Revenue hold office in Metro Manila (National Capital Judicial Region), and the BIR Regional Office is in Cagayan de Oro City (10th Judicial Region), while Judge Flores’s court is in Tubod, Lanao del Norte (12th Judicial Region). His TRO and writ of preliminary injunction had no extraterritorial effect.
– Judge Flores’s claim of good faith was rejected, as gross ignorance of the law cannot be excused by good faith when the error is basic and patent. The Court emphasized that ignorance of the rules on jurisdiction is inexcusable and produces an inference of bad faith.
2. Manifest Partiality: The charge of manifest partiality was dismissed. The Court found that complainants failed to provide clear evidence of bias or partiality. The mere issuance of orders favorable to one party does not constitute partiality in the absence of proof of corrupt or malicious intent.
3. Denial of Due Process: The charge of denial of due process was dismissed. The Court held that treating the comment filed via LBC as a mere scrap of paper was a procedural error but did not amount to a denial of due process, as the respondents were still given opportunities to be heard in subsequent proceedings.
4. Conduct Prejudicial to the Best Interest of the Service: This charge was dismissed due to lack of evidence. The Court noted that conduct prejudicial to the service involves acts that tarnish the judiciary’s image, but complainants did not allege any similar misconduct by Judge Flores.
PENALTY: Judge Alan L. Flores was SUSPENDED from office without salary and other benefits for three months and one day, with a WARNING that similar acts in the future would be dealt with more severely.