G.R. No. RTJ-15-2423. January 11, 2017.
SANTIAGO D. ORTEGA, JR., Complainant, vs. JUDGE ROGELIO LL. DACARA, Respondent.

FACTS

Complainant Santiago D. Ortega, Jr., as president of Siramag Fishing Corporation (SFC), filed a case for Damages with an Application for a Writ of Preliminary Mandatory Injunction against certain BFAR officials. The case was raffled to respondent Judge Rogelio Ll. Dacara’s court, RTC Branch 37 in Iriga City. Judge Dacara denied the application for the writ in an Order dated April 22, 2013. The Order cited three grounds: the plaintiffs failed to show a clear right; the court was prohibited from issuing the injunction under P.D. No. 605 and A.M. No. 09-6-8-SC; and the court lacked territorial jurisdiction over the defendants, whose office was in Pili, Camarines Sur.
The complainant alleged gross ignorance of the law, arguing that the cited prohibition applies only to preliminary prohibitory injunctions, not mandatory ones. He also contended that an RTC can issue a writ enforceable anywhere within its judicial region, which includes Pili. Furthermore, he asserted that the judge should not have taken cognizance of the case as his sala was not a designated environmental court. In his defense, Judge Dacara maintained that a mandatory injunction was included in the prohibition, and he acted in good faith regarding the jurisdictional and environmental court issues.

ISSUE

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

RULING

Yes, but only concerning the erroneous ruling on territorial jurisdiction. The Supreme Court found that Judge Dacara’s denial of the writ based on the substantive legal prohibitions and the complainant’s failure to establish a clear right constituted a valid exercise of judicial discretion, not gross ignorance. An error on a debatable point of law, such as the applicability of a statutory prohibition to a mandatory injunction, is generally a judicial error correctable by appeal, not an administrative offense.
However, the Court held that the judge committed gross ignorance of the law regarding territorial jurisdiction. Section 21 of B.P. Blg. 129 explicitly provides that Regional Trial Courts can issue writs of injunction enforceable anywhere within their respective judicial regions. RTC Branch 37 of Iriga City and the Municipality of Pili are both within the Fifth Judicial Region. Judge Dacara’s insistence that he lacked jurisdiction over defendants in Pili demonstrated a blatant disregard of this basic, settled rule. Such a fundamental error transcends mere misjudgment and constitutes gross ignorance, warranting administrative sanction. Considering his compulsory retirement, the Court imposed a fine of Twenty Thousand Pesos (₱20,000) to be deducted from his retirement benefits.