A.M. No. RTJ-22-022 [Formerly OCA I.P.I. No. 19-4966-RTJ]. August 23, 2022.
Governor Edgardo A. Tallado, et al., complainants, vs. Hon. Winston S. Racoma, Presiding Judge, Branch 39, Regional Trial Court, Daet, Camarines Norte, respondent.

FACTS

The case originated from a protracted administrative dispute involving local officials of Camarines Norte. The Sangguniang Panlalawigan (SP) found Mayor Senandro Jalgalado guilty of Grave Abuse of Authority and ordered his six-month suspension. Governor Edgardo Tallado, after securing an exemption from the Commission on Elections, issued the Notice of Suspension. Mayor Jalgalado challenged this suspension before the Regional Trial Court (RTC) via a Petition for Certiorari, Prohibition, and Mandamus, which was raffled to Branch 39 presided by respondent Judge Winston S. Racoma. The complainants, Governor Tallado and members of the SP, filed a Manifestation with Motion for Inhibition, arguing that the RTC lacked jurisdiction as petitions for certiorari against decisions of the SP should be filed directly with the Court of Appeals under Rule 65 of the Rules of Court. Despite this jurisdictional challenge, Judge Racoma proceeded to hear the case. After a hearing where parties submitted their pleadings for resolution, Judge Racoma issued an Order dated April 25, 2019, granting Mayor Jalgalado’s prayer for a writ of preliminary injunction, thereby enjoining the implementation of the SP’s suspension order.

ISSUE

Whether respondent Judge Racoma is administratively liable for Gross Ignorance of the Law for taking cognizance of and issuing a preliminary injunction in a petition for certiorari that assailed a decision of the Sangguniang Panlalawigan, despite clear jurisprudence vesting exclusive appellate jurisdiction over such decisions in the Court of Appeals.

RULING

Yes, Judge Racoma is guilty of Gross Ignorance of the Law. The Supreme Court emphasized that ignorance of settled jurisprudence constitutes gross ignorance of the law. The law is unequivocal: under Section 4 of Rule 65 of the Rules of Court, and as consistently held by the Court, a petition for certiorari seeking to nullify a decision of the Sangguniang Panlalawigan in an administrative case against a municipal mayor is within the exclusive original jurisdiction of the Court of Appeals, not the Regional Trial Court. Judge Racoma’s failure to apply this basic and well-settled rule was inexcusable. His defense that he was merely following a prior temporary restraining order from another branch was rejected, as a judge is expected to resolve jurisdictional issues independently. By proceeding to hear the case and grant injunctive relief despite the patent lack of jurisdiction, he exhibited a gross lack of familiarity with the law. Such act constitutes gross ignorance of the law, which is a serious charge under Rule 140 of the Rules of Court. The Court found that his actions were not mere error of judgment but a blatant disregard of fundamental legal principles. Accordingly, the Court imposed a fine of Forty Thousand Pesos (P40,000.00) upon Judge Racoma, with a stern warning that a repetition of the same or similar act would be dealt with more severely.