G.R. No. RTJ-15-2407. November 22, 2017.
EDGAR R. ERICE, Complainant vs. PRESIDING JUDGE DIONISIO C. SISON, REGIONAL TRIAL COURT, BRANCH 125, CALOOCAN CITY, Respondent.

FACTS

Complainant Edgar Erice, then Vice-Mayor of Caloocan City, filed an administrative case before the Ombudsman against city officials, resulting in a preventive suspension order. The Court of Appeals affirmed this order. Despite this, the suspended officials filed a Petition for Declaratory Relief with the RTC of Caloocan City, praying for a judicial declaration on the implementation of their suspension, naming Erice and the DILG as respondents. The case was eventually raffled to respondent Judge Dionisio Sison.
During summary hearings, Erice and the DILG questioned the RTC’s jurisdiction, citing a pending motion for reconsideration with the CA and the Ombudsman’s primary jurisdiction. Judge Sison proceeded with the hearings, denied the government counsel’s right to cross-examine witnesses, and extended a 72-hour TRO to 20 days. He subsequently granted a writ of preliminary injunction against the implementation of the Ombudsman’s suspension order, without first resolving the pending motion to dismiss and motion for inhibition filed against him.

ISSUE

Whether respondent Judge Sison is administratively liable for Gross Ignorance of the Law.

RULING

Yes, Judge Sison is guilty of Gross Ignorance of the Law. The Supreme Court affirmed the OCA’s findings. The legal logic is clear: jurisdiction is conferred by law. Under Section 14 of Republic Act No. 6770 (The Ombudsman Act), no court, except the Supreme Court, shall hear any appeal or application for remedy against a decision of the Ombudsman. Furthermore, no writ of injunction shall be issued to delay an Ombudsman investigation. By entertaining the Petition for Declaratory Relief which sought to enjoin the implementation of the Ombudsman’s affirmed order, Judge Sison arrogated unto himself a power expressly withheld from lower courts.
His actions demonstrated a blatant disregard for basic, elementary, and well-known legal principles. His defense that he acted due to time constraints under the Rules of Court is untenable; procedural rules cannot override a substantive statutory prohibition on jurisdiction. His failure to resolve the foundational challenge to his jurisdiction before issuing injunctive relief compounded the error. Such ignorance of settled law constitutes gross ignorance, which is a serious charge. Considering his retirement, the Court imposed a fine of One Hundred Thousand Pesos (₱100,000.00) to be deducted from his retirement benefits.