G.R. No. RTJ-99-1484 (A) and RTJ-99-1484. March 17, 2000.
Joselito Rallos, et al. and Executive Secretary Ronaldo B. Zamora, complainants, vs. Judge Ireneo Lee Gako Jr., RTC, Branch 5, Cebu City, respondent.

FACTS

Two administrative complaints were consolidated against Judge Ireneo Lee Gako Jr. The first, by Executive Secretary Ronaldo Zamora, charged him with ignorance of the law and grave abuse of authority. This stemmed from his order to release 25,000 sacks of imported rice to private claimants in Civil Case No. CEB-23077, despite pending seizure and forfeiture proceedings before the Bureau of Customs. Judge Gako denied the Bureau’s motion to dismiss, ruled it lacked jurisdiction as the goods were apprehended outside the customs zone, and granted a writ of preliminary injunction for the rice’s release.
The second complaint was filed by the Rallos heirs in Special Proceedings Case No. 1576-R, concerning the estate of Simeon Rallos. They assailed Judge Gako’s Order dated March 15, 1999, which falsely stated that the complainants and their counsel were present and notified in open court during a hearing on that date. In truth, they were absent and had received no prior notice. The judge later admitted the error, attributing it to a “mental lapse” and claiming he had intended to schedule the hearing for March 17.

ISSUE

Whether respondent Judge Ireneo Lee Gako Jr. is administratively liable for his actions in the rice seizure case and the estate proceedings.

RULING

Yes, Judge Gako is administratively liable. Regarding the first charge, the Supreme Court found him guilty of gross ignorance of the law. Well-settled jurisprudence holds that regional trial courts have no jurisdiction to interfere with seizure and forfeiture proceedings instituted by the Bureau of Customs, which exercises exclusive jurisdiction over such matters. By taking cognizance of the injunction case and ordering the release of the goods, Judge Gako disregarded this established doctrine. His defense of good faith was untenable, as the legal principle was basic and left no room for doubt or misapplication.
Concerning the second charge, the Court found Judge Gako guilty of dishonesty and conduct prejudicial to the administration of justice. His false statement in the March 15 Order regarding the complainants’ presence was not a mere innocent mistake. His subsequent attempt to correct it only upon being challenged, and his implausible claim of a “mental lapse,” indicated an intent to mislead and cover up a procedural irregularity. Such dishonesty undermines public confidence in the judiciary. Considering both infractions, the Court imposed a fine of Forty Thousand Pesos (P40,000.00) with a stern warning.