The Supreme Court (SC) has declared it will always be “vigilant in protecting judges and justices against administrative cases filed against them that are meant solely to harass, embarrass, or vex them.”
It dismissed the administrative complaint against Regional Trial Court (RTC) Judge Winston S. Racoma and ordered the complainants, who were then ranking provincial officials of Camarines Norte, to explain why they should not be held for indirect contempt of court for prematurely filing a complaint that was “intended to harass or vex” the judge.
Ordered to explain in 10 days from receipt of notice were former Camarines Norte Gov. Edgardo A. Tallado, Vice Gov. Jonah Pedro P. Pimentel, and Provincial Board Members Rodolfo V. Gache, Stanley B. Alegre, Renee F. Herrera, Gerardo G. Quinones, Reynor V. Quibral, Erwin L. Lausin, Artemio B. Serdon Jr., Jay G. Pimentel, and Ramon R. Baning.
Indirect contempt of court is punishable with a fine or prison term of six months, or both fine and imprisonment.
The SC’s unanimous full court decision, which was made public last Sept. 28, was written by Associate Justice Maria Filomena D. Singh.
Case records showed that in 2019 when Tallado and the provincial board members were still incumbent officials, they filed an administrative case against Judge Racoma for gross ignorance of the law and procedure and gross misconduct.
In 2015, Barangay officials Leslie B. Esturas and Moises Delos Santos Jr. were charged administratively before the Sangguniang Bayan of Capalong town in Camarines Norte.
Then Capalong Mayor Senandro M. Jalgalado ordered the preventive suspension for 60 days of the two barangay officials who appealed the suspension before the Sangguniang Panlalawigan.
In 2016, the Sangguniang Panlalawigan granted the appeal and ordered the reinstatement of the two barangay officials. Mayor Jalgalado did not implement the decision of the Sangguniang Panlalawigan as he pointed out that Tallado was under preventive suspension at that time and had no authority to approve and enforce the reinstatement decision.
On Dec. 18, 2018, the Sangguniang Panlalawigan recommended the 60-day preventive suspension of Jalgalado for his defiance to implement the reinstatement decision. The recommendation was approved by Tallado who issued the notice of preventive suspension against Jalgalado.
Mayor Jalgalado challenged the preventive suspension in a petition filed before the RTC in Daet, Camarines Norte. RTC Judge Arniel A. Dating stopped the implementation of the suspension order.
Jalgalado then asked the suspension of proceedings filed against him by the two barangay officials and pointed out that the Local Government Code prohibits the investigation of an elective official in an administrative complaint within 90 days prior to a local election.
Aside from denying Jalgalado’s motion, the Sangguniang Panlalawigan resolved the complaint and ordered the mayor’s suspension for six months. On April 4, 2019, Tallado issued the six-month suspension order.
Jalgalado challenged his six-month suspension before the Daet RTC. The case originally landed in the sala of Judge Dating but with the judge’s inhibition, the case was assigned to Judge Racoma after raffle.
Tallado and the Sangguniang Panlalawigan members sought Racoma’s inhibition and pleaded for the dismissal of Jalgalado’s petition. During the April 23, 2019 hearing, Tallado and his group manifested that it is the Court of Appeals (CA), not the RTC, which has jurisdiction over the case.
On April 25, 2019, Judge Racoma stopped the enforcement of the six-month suspension of Jalgalado who was ordered to post an injunction bond of P100,000.
Judge Racoma ruled that Jalgalado’s suspension, which fall within the 90-day period before the 2019 local elections, will strip the mayor of his rights and obligations to carry out the duty of his office and serve his constituents.
On April 26, 2019, Racoma inhibited himself from the case. A check with Court Administrator Raul B. Villanueva of the SC’s Office of the Court Administrator showed that Judge Racoma had retired compulsorily on Feb. 16, 2022.
Instead of filing a motion to reconsider Racomas’ April 25, 2019 order, Tallado and his group filed the administrative case against the judge. They claimed that the judge committed gross ignorance of the law and procedure when he took cognizance of Jalgalado’s petition in which the CA, not the RTC, has jurisdiction.
In its report dated April 20, 2022, the Judicial Integrity Board (JIB) found Racoma guilty of gross ignorance of the law and procedure and recommended a fine of P200,000.
The JIB said that the Sangguniang Panlalawigan is considered by the Local Government Code as a quasi-judicial body, and that Judge Racoma should not have taken cognizance of Jalgalado’s petition in which the CA has jurisdiction.
“The Court (SC) rejects the recommendation of the JIB, and dismisses the charge of gross ignorance of the law against Judge Racoma,” the SC ruled.
Citing its previous decisions, the SC said:
“Errors committed by a judge in the exercise of his or her adjudicative functions cannot be corrected through administrative proceedings, but should instead be assailed through available judicial remedies.
“It is well-settled that disciplinary proceedings and criminal actions against judges are not complementary or suppletory to, nor a substitute for, these judicial remedies, whether ordinary or extraordinary.
“For, obviously, if subsequent developments prove the judge's challenged act to be correct, there would be no occasion to proceed against him at all.
“Besides, to hold a judge administratively accountable for every erroneous ruling or decision he renders, assuming he has erred, would be nothing short of harassment and would make his position doubly unbearable.
“To hold otherwise would be to render judicial office untenable, for no one called upon to try the facts or interpret the law in the process of administering justice can be infallible in his judgment.
“It is only where the error is tainted with bad faith, fraud, malice, or dishonesty that administrative sanctions may be imposed against the erring judge.
“Considering that the administrative complaint filed by the Complainants pertains to the exercise of Judge Racoma's adjudicative functions, the Complainants should have first exhausted judicial remedies instead of immediately resorting to administrative proceedings.
“In any case, whether Judge Racoma gravely abused his discretion or otherwise erred in taking cognizance of the Petition for Certiorari filed by Mayor Jalgalado, docketed as Civil Case No. 8403, does not necessarily translate to an administrative violation unless there is a clear showing of bad faith on his part.
“Our judges do not perform their judicial duties in a vacuum. They, like us, assume their role in society and, as such, necessarily interact and relate with other members of their communities.
“The Court takes judicial notice that Judge Racoma is up against powerful individuals whom we can assume wield great power and influence in his place of work. This is not the first case filed against Judge Racoma by the Complainants as there are other administrative cases that have been filed against him by the same or related individuals.
“The Court likewise takes note that Judge Racoma is not the only judge who has been sued by the politicians in his province. The Executive Judge, Judge ArnieI A. Dating, the Presiding Judge of Branch 41 of the RTC ofDaet, Camarines Norte, has also been named a respondent in several cases filed by Complainants Tallada, et al.
“Judge Dating was the first judge who acted in the case subject matter of this Petition until he inhibited and the case was re-raffled to Judge Racoma, and Tallada, et al. filed the present administrative charge against him as a result.
“There are only three (3) RTC Judges in Daet, Camarines Norte, and one (1) Family Court Judge. It should concern the Court that the Complainants, for this one case, had already 'eliminated' and sued two (2) of the judges in the station, leaving only one more to act on it. This kind of situation is to be decried, though not uncommon.
“The influence of both elective and appointive officials on our judges is a fact we must not close our eyes to. We have our Code of Judicial Conduct to guide us in navigating the tenuous balance in our relations with the officials from the two other branches of government.
“However, not even the Code can protect our judicial frontliners from the hardships occasioned by discordant and, more so, openly adversarial relations with the said officials. Unfortunately, the filing of administrative charges against our judges has been unscrupulously resorted to.
“Whereas, the members of this Court are no less vulnerable, we must acknowledge that our judges have to literally face and live in the midst of this unhealthy environment, day in and day out. Certainly, in discharging the Court's duty of supervision, we must take these matters into account, specially so in deciding administrative cases which may have been actuated by obviously long-standing strained relations, if not outright animosity.
“Indeed, unfounded criticisms against members of the Judiciary degrade the judicial office and greatly interfere with the due performance of their functions in the Judiciary.
“They not only needlessly drain the resources of the Court in resolving them, they sow the seeds of distrust of the public against members of the Judiciary. Hence, the Court deems it proper to direct the Complainants to explain their act of filing a premature complaint against Judge Racoma intended to harass or vex the latter.
“The Court is cognizant of the sacrifices of our judges, who risk their very lives and even those of their loved ones, in order to keep our courts open and render the services our people need. None of them is perfect. Just as none of us are. When they commit errors, it is our duty to correct them.
“But when their circumstances call out for consideration, we must not turn a blind eye. Judge Racoma has not been previously convicted of the charge against him, that is, Gross Ignorance of the Law and Procedure. Judge Racoma, more notably, has never been found guilty of committing any corrupt act in all his past cases. That should merit great weight.
“Concededly, Judge Racoma was convicted twice for insubordination for failing to file his comment in two of the cited administrative cases. It is disturbing to think and would be truly tragic if Judge Racoma' s reason for not submitting a comment in those cases (where he was acquitted of the charges and cited for insubordination instead for such non-filing of a comment) is his loss of hope, his despair over the pressures of his work and the seeming lack of recognition of such plight.
“A judge who discharges his or her duties despite being beset with external pressures, and who manages to fend off corrupt influences and remain true to his or her oath, save only for an occasional error in judgment, should be extended consideration and commiseration, not condemnation.
“WHEREFORE, the administrative Complaint against respondent Judge Winston S. Racoma, Presiding Judge, Branch 39, Regional Trial Court, Daet, Camarines Norte is DISMISSED. The Complainants, Governor Edgardo A. Tallado, Vice Governor Jonah Pedro P. Pimentel, Board Member Rodolfo V. Gache, Board Member Stanley G. Alegre, Board Member Renee F. Herrera, Board Member Gerardo G. Quinones, Board Member Reynor V. Quibral, Board Member Erwin L. Lausin, Board Member Artemio B. Serdon, Jr., Board Member Jay G. Pimentel, and Board Member Ramon R. Baning are ORDERED to SHOW CAUSE within ten (10) days from notice why they should not be held for indirect contempt of court for filing a premature complaint against Judge Winston S. Racoma intended to harass or vex the latter. SO ORDERED.”