In the recent case of HEIRS OF SIMEON PIEDAD, et. al. vs. EXECUTIVE JUDGE CESAR O. ESTRERA and JUDGE GAUDIOSO D. VILLARIN, En Banc, A.M. No. RTJ-09-2170 [Formerly OCA I.P.I. No. 09-3094-RTJ], December 16, 2009, the Philippine Supreme Court found the respondents Judge Cesar O. Estrera and Judge Gaudioso D. Villarin of the RTC in Toledo City, Cebu, Branches 29 and 59, respectively, GUILTY of GROSS IGNORANCE OF THE LAW and imposed upon them a FINE in the amount of twenty one thousand pesos (PhP 21,000) each, with the stern warning that a repetition of similar or analogous infractions in the future shall be dealt with more severely. Also, the Court found Judge Gaudioso D. Villarin GUILTY of UNDUE DELAY IN RENDERING AN ORDER and imposed upon him a FINE in the additional amount of eleven thousand pesos (PhP 11,000). In the said case, the Court made the following doctrinal pronouncements (which are basically reiterations of existing Philippine jurisprudence on the ethical and legal issues involved):
1. The acts of respondent Judge Estrera in issuing a TRO and of respondent Judge Villarin in extending the TRO disregard the basic precept that no court has the power to interfere by injunction with the judgments or orders of a co-equal and coordinate court of concurrent jurisdiction having the power to grant the relief sought by injunction.
2. The Court laid down the doctrine that “no court has power to interfere by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction having power to grant the relief sought by injunction.”
3. The various branches of the court of first instance of a province or city, having as they have the same or equal authority and exercising as they do concurrent and coordinate jurisdiction, should not, cannot and are not permitted to interfere with their respective cases, much less with their orders or judgments. A contrary rule would obviously lead to confusion and seriously hamper the administration of justice.
4. Undue interference by one in the proceedings and processes of another is prohibited by law. The doctrine of judicial stability or non-interference in the regular orders or judgments of a co-equal court, as an accepted axiom in adjective law, serves as an insurmountable barrier to the competencia of the RTC Cebu City to entertain a motion, much less issue an order, relative to the Silverio share which is under the custodia legis of RTC Makati City, Branch 64, by virtue of a prior writ of attachment.
5. Jurisdiction is vested in the court not in any particular branch or judge, and as a corollary rule, the various branches of the Court of First Instance of a judicial district are a coordinate and co-equal courts one branch stands on the same level as the other. Undue interference by one on the proceedings and processes of another is prohibited by law. In the language of this Court, the various branches of the Court of First Instance of a province or city, having as they have the same or equal authority and exercising as they do concurrent and coordinate jurisdiction should not, cannot, and are not permitted to interfere with their respective cases, much less with their orders or judgments.
6. It cannot be gainsaid that adherence to a different rule would sow confusion and wreak havoc on the orderly administration of justice, and in the ensuing melee, hapless litigants will be at a loss as to where to appear and plead their cause.
7. Clearly, when the respondents-judges acted on the application for the issuance of a TRO, they were aware that they were acting on matters pertaining to a co-equal court, namely, Branch 9 of the Cebu City RTC, which was already exercising jurisdiction over the subject matter in Civil Case No. 435-T. Nonetheless, respondents-judges still opted to interfere with the order of a co-equal and coordinate court of concurrent jurisdiction, in blatant disregard of the doctrine of judicial stability, a well-established axiom in adjective law.
8. As members of the judiciary, respondents-judges ought to know the fundamental legal principles; otherwise, they are susceptible to administrative sanction for gross ignorance of the law. As a judge, the respondent must have the basic rules at the palm of his hands as he is expected to maintain professional competence at all times. Judges should be diligent in keeping abreast with developments in law and jurisprudence, and regard the study of law as a never-ending and ceaseless process. Elementary is the rule that when laws or rules are clear, it is incumbent upon the respondent to apply them regardless of personal belief and predilections. To put it differently, when the law is unambiguous and unequivocal, application not interpretation thereof is imperative. Indeed, a judge is called upon to exhibit more than just a cursory acquaintance with statutes and procedural rules. He must be conversant with basic legal principles and well-settled doctrines. He should strive for excellence and seek the truth with passion. The failure to observe the basic laws and rules is not only inexcusable, but renders him susceptible to administrative sanction for gross ignorance of the law from which no one is excused, and surely not a judge.
9. If respondent Judge Villarin indeed believed that the motions pending before him were defective, he could have simply acted on the said motions and indicated the supposed defects in his resolutions instead of just leaving them unresolved.
10. Undue delay in the disposition of cases and motions erodes the faith and confidence of the people in the judiciary and unnecessarily blemishes its stature. No less than the Constitution mandates that lower courts must dispose of their cases promptly and decide them within three months from the filing of the last pleading, brief or memorandum required by the Rules of Court or by the Court concerned. In addition, a judge's delay in resolving, within the prescribed period, pending motions and incidents constitutes a violation of Rule 3.05 of the Code of Judicial Conduct requiring judges to dispose of court business promptly.
11. There should be no more doubt that undue inaction on judicial concerns is not just undesirable but more so detestable especially now when our all-out effort is directed towards minimizing, if not totally eradicating the perennial problem of congestion and delay long plaguing our courts. The requirement that cases be decided within the reglementary period is designed to prevent delay in the administration of justice, for obviously, justice delayed is justice denied. An unwarranted slow down in the disposition of cases erodes the faith and confidence of our people in the judiciary, lowers its standards and brings it into disrepute.
