The Supreme Court in Erice v. Sison ruled that judges cannot interfere with decisions of the Ombudsman that are appealable to the Court of Appeals. Judge Sison was found guilty of gross ignorance of the law for issuing a temporary restraining order and a writ of preliminary injunction against the implementation of the Ombudsman’s order suspending public officials. This decision underscores the importance of judicial stability and respect for the jurisdiction of quasi-judicial bodies, reinforcing that lower courts should not overstep their authority by interfering with decisions that are properly within the appellate jurisdiction of higher courts.

When Can a Judge be Held Liable for Gross Ignorance of the Law?

This case arose from an administrative complaint filed by Edgar R. Erice against Judge Dionisio C. Sison for gross misconduct and ignorance of the law. The central issue involves whether Judge Sison acted improperly by issuing injunctive reliefs that effectively interfered with an order from the Ombudsman, which had already been affirmed by the Court of Appeals (CA). The controversy began when Erice, then Vice Mayor of Caloocan City, filed a complaint against Mayor Enrico R. Echiverri and other city officials for violations of the Government Service Insurance System Act, leading to the Ombudsman issuing an order of preventive suspension against Echiverri and his co-accused.

Echiverri, et al., challenged the suspension order before the CA, but the appellate court affirmed the Ombudsman’s decision. Undeterred, Echiverri, et al., then filed a Petition for Declaratory Relief with Prayer for TRO and/or Writ of Preliminary Injunction with the Regional Trial Court (RTC) of Caloocan City, seeking a judicial declaration on the rights and obligations of the parties concerning the suspension’s implementation. Initially, a 72-hour ex-parte TRO was issued, and the case was eventually assigned to Judge Sison after another judge inhibited. Despite motions to dismiss questioning the RTC’s jurisdiction and alleging forum shopping, Judge Sison extended the TRO and ultimately granted a writ of preliminary injunction, effectively preventing the enforcement of the Ombudsman’s suspension order.

In response to the administrative charges, Judge Sison defended his actions by asserting that he accorded due process to Echiverri, et al. by allowing them to present their case and that the TRO was extended to allow for a thorough review of the issues. He also claimed that there was no basis for allegations of bias or partiality. However, the Office of the Court Administrator (OCA) found Judge Sison guilty of gross ignorance of the law, citing his violation of Section 14 of Republic Act No. (RA) 6770, also known as the Ombudsman Act of 1989, which restricts courts from issuing injunctions to delay investigations by the Ombudsman.

Section 14 of RA 6770 explicitly states:

SEC. 14. Restrictions. — No writ of injunction shall be issued by any court to delay an investigation being conducted by the Ombudsman under this Act, unless there is a prima facie evidence that the subject matter of the investigation is outside the jurisdiction of the Office of the Ombudsman.

No court shall hear any appeal or application for remedy against the decision or findings of the Ombudsman, except the Supreme Court, on pure question of law.

The Supreme Court, in its analysis, agreed with the OCA’s findings, highlighting that Judge Sison’s actions contravened established legal principles. Even though the Court in Carpio Morales v. Court of Appeals declared Section 14(2) of RA 6770 unconstitutional and deemed the policy in Section 14(1) as ineffective, this did not absolve Judge Sison of liability. The Court emphasized the principle of judicial stability or non-interference, which dictates that courts should not interfere with the decisions of administrative bodies, like the Ombudsman, whose decisions are appealable to the CA. This principle recognizes the co-equal status of these bodies and prevents lower courts from overstepping their jurisdiction.

The Court noted that decisions of the Ombudsman in disciplinary cases are appealable to the CA under Rule 43 of the Rules of Court. Therefore, the RTC had no jurisdiction to interfere with or restrain the execution of the Ombudsman’s decisions. Significantly, at the time Judge Sison issued the TRO and proceeded with the writ of preliminary injunction, the CA had already affirmed the Ombudsman’s Order of Suspension. This prior affirmation further underscored the impropriety of Judge Sison’s actions. Moreover, the Supreme Court also pointed out that court orders or decisions cannot be the subject matter of a petition for declaratory relief, as such reliefs are intended for ambiguous written instruments, not judicial pronouncements.

The Court explained that a petition for declaratory relief is governed by Rule 63 of the Rules of Court, which specifies that it applies to deeds, wills, contracts, or other written instruments, and not to court judgments or decisions. This restriction is based on the principle of res judicata, which prevents the relitigation of issues already decided by a competent court. In this case, Echiverri, et al., sought a judicial declaration on the implementation of the preventive suspension, effectively challenging the CA-affirmed Ombudsman order, which was beyond the RTC’s jurisdictional purview. The Supreme Court ultimately found Judge Sison guilty of gross ignorance of the law, imposing a fine of Forty Thousand Pesos (P40,000.00), to be deducted from his terminal leave benefits.

The penalty for gross ignorance of the law, as stipulated under Rule 140 of the Rules of Court as amended by A.M. No. 01-8-10-SC, includes sanctions ranging from a fine to dismissal. Given Judge Sison’s retirement, the imposition of suspension was not feasible, leading to the imposition of a fine. The Court also considered that this was not Judge Sison’s first offense, justifying the imposition of a higher fine. This case serves as a reminder of the importance of judges adhering to fundamental legal principles and respecting the jurisdictional boundaries between different adjudicative bodies, ensuring the integrity and stability of the judicial system.

FAQs

What was the key issue in this case?	The key issue was whether Judge Sison was guilty of gross ignorance of the law for issuing injunctive reliefs that interfered with an order from the Ombudsman, which had already been affirmed by the Court of Appeals.
What is the significance of Section 14 of RA 6770?	Section 14 of RA 6770, also known as the Ombudsman Act of 1989, restricts courts from issuing injunctions to delay investigations conducted by the Ombudsman, unless there is prima facie evidence that the subject matter is outside the Ombudsman’s jurisdiction. This provision aims to protect the Ombudsman’s investigative authority.
What is the principle of judicial stability or non-interference?	The principle of judicial stability or non-interference dictates that courts should not interfere with the decisions of administrative bodies, like the Ombudsman, whose decisions are appealable to higher courts such as the Court of Appeals. This promotes respect for the hierarchical structure of the judiciary.
Why was Judge Sison found guilty of gross ignorance of the law?	Judge Sison was found guilty because he issued a TRO and writ of preliminary injunction against the enforcement of the Ombudsman’s suspension order, even though the CA had already affirmed that order. This action violated the principle of non-interference and Section 14 of RA 6770.
What is a Petition for Declaratory Relief and what are its limitations?	A Petition for Declaratory Relief is an action to determine the rights and obligations of parties under a written instrument, statute, or regulation before a breach occurs. It cannot be used to question or modify existing court orders or decisions, as that would violate the principle of res judicata.
What is res judicata and how does it apply in this case?	Res judicata is a legal principle that prevents the relitigation of issues that have already been decided by a competent court or quasi-judicial body. In this case, it prevented Echiverri, et al. from using a Petition for Declaratory Relief to challenge the CA-affirmed Ombudsman order.
What was the penalty imposed on Judge Sison?	Given that Judge Sison had already retired, the Supreme Court imposed a fine of Forty Thousand Pesos (P40,000.00), which was to be deducted from his terminal leave benefits. This was deemed appropriate given his violation of legal principles and the fact that it was not his first offense.
What does this case teach about the jurisdiction of the RTC?	This case underscores that the RTC does not have jurisdiction to interfere with decisions of the Ombudsman in disciplinary cases that are appealable to the Court of Appeals. It reinforces the importance of judges respecting jurisdictional boundaries.

The decision in Erice v. Sison reinforces the importance of adhering to legal principles and respecting the jurisdictional boundaries of various adjudicative bodies. It serves as a crucial reminder for judges to remain vigilant in upholding the law and to avoid actions that could undermine the integrity and stability of the judicial system. Ensuring adherence to these principles is crucial for maintaining public trust and confidence in the administration of justice.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: EDGAR R. ERICE v. PRESIDING JUDGE DIONISIO C. SISON, G.R. No. 63742, November 22, 2017