IPI No. 17-256-CA-J. February 18, 2020.
RE: COMPLAINT-AFFIDAVIT OF NORBERTO B. VILLAMIN AND EDUARDO A. BALCE AGAINST ASSOCIATE JUSTICES RAMON M. BATO, JR., ZENAIDA T. GALAPATE-LAGUILLES AND MARIA ELISA SEMPIO DIY OF THE SPECIAL TWELFTH DIVISION; AND ASSOCIATE JUSTICE MARIE CHRISTINE AZCARRAGA-JACOB OF THE SPECIAL THIRD DIVISION, BOTH OF THE COURT OF APPEALS, RELATIVE TO CA-G.R. SP NO. 147998 AND CA-G.R. SP NO. 148108.

FACTS

Complainants Norberto B. Villamin and Eduardo A. Balce filed a Complaint-Affidavit against several Court of Appeals (CA) Associate Justices for grave abuse of discretion, gross ignorance of the law, and gross incompetence. The complaint stemmed from two separate CA Resolutions granting interim reliefs to then Governor Edgardo A. Tallado of Camarines Norte in petitions assailing Ombudsman decisions.
In the first case (CA-G.R. SP No. 147998), the CA Special 12th Division (Justices Bato, Jr., Galapate-Laguilles, and Sempio Diy) issued a Resolution dated December 16, 2016, granting Tallado’s petition and issuing a writ of preliminary mandatory injunction. This enjoined the implementation of an Ombudsman Decision (OMB-L-A-15-0101) which found Tallado administratively liable for disgraceful and immoral conduct and suspended him for six months and one day. The CA held that the immediate implementation would cause irreparable injury to Tallado and his constituents, and that Tallado presented a clear right to be protected pending resolution of his petition on the merits regarding the sufficiency of evidence.
In the second case (CA-G.R. SP No. 148108), the CA Special 3rd Division (Justices Carandang, Lopez, and Azcarraga-Jacob) issued a Resolution dated December 12, 2016, granting Tallado’s petition and issuing a 60-day Temporary Restraining Order (TRO). This enjoined the implementation of another Ombudsman Decision (OMB-L-A-15-0480) which found Tallado guilty of grave misconduct and oppression/abuse of authority and dismissed him from service. The CA cited the gravity of the penalty and raised the paramount issue of whether the condonation doctrine applied, noting the prospective application of its abandonment was unclear as the acts complained of were committed in 2010 and Tallado had been re-elected since.
Subsequently, the Court En Banc dropped Justices Rosmari D. Carandang and Mario V. Lopez as respondents in the administrative case because, as members of the Supreme Court, they are impeachable officers and can only be disciplined through impeachment. The Court proceeded to rule on the complaint against the remaining CA Justices.

ISSUE

Whether the Associate Justices of the Court of Appeals of the Special Twelfth and Special Third Division are guilty of grave abuse of discretion, gross ignorance of the law, and gross incompetence.

RULING

The Court DISMISSED the administrative complaint for lack of merit.
The Court held that the issuance of the writ of preliminary injunction and the TRO by the CA Divisions were within their sound discretion and were exercises of their ancillary jurisdiction to prevent irreparable injury and preserve the status quo pending the resolution of the main petitions. The Justices’ actions were based on their judicious assessment of the factual and legal circumstances, including the potential injury to Tallado and his constituents, and the novel legal question regarding the application of the condonation doctrine. The Court emphasized that an administrative complaint is not the proper remedy to correct actions of a judge perceived to be erroneous; these should be raised through judicial remedies like a motion for reconsideration or a petition for certiorari. For a judge to be held administratively liable, the error must be gross, deliberate, and malicious, or incurred with bad faith, dishonesty, or corruption. Mere errors of judgment, absent proof of ill motive, are not subject to disciplinary action. The complainants failed to substantiate their allegations of bad faith or gross ignorance. The Court further noted that judges should be protected from unfounded administrative complaints to preserve judicial independence.