A.M. No. RTJ-05-1959 December 9, 2005 Court of Appeals which reversed the trial court’s ruling 5.

e trial court’s ruling 5. Ordering the plaintiff, upon payment of the just
and remanded the case to the trial court for further compensation for the acquisition of her property, to
(Formerly OCA I.P.I. No. 04-1941-RTJ)
proceedings. The Supreme Court sustained the Court of execute the necessary deed of conveyance in favour of
REPUBLIC OF THE PHILIPPINES, Complainant,  Appeals decision. the defendant Republic of the Philippines and, on the
vs. other hand, directing the defendant Register of Deeds,
Upon the inhibition of the presiding Judge of the Manila
JUDGE VICENTE A. HIDALGO, Presiding Judge of the upon presentation of the said deed of conveyance, to
RTC (Branch 35), the case was re-raffled to the Manila
Regional Trial Court of Manila, Branch 37,Respondent. cancel plaintiff’s Transfer Certificate of Title in favour of
RTC (Branch 37), with respondent Vicente A. Hidalgo as
the defendant Republic of the Philippines;
DECISION presiding Judge.
6. Ordering the defendant Republic of the Philippines to
CHICO-NAZARIO, J.: In an Order dated 07 July 2003, Judge Hidalgo declared
pay the plaintiff the sum of ONE BILLION FOUR HUNDRED
the Republic in default for failure of Solicitor Gabriel
The instant administrative case arose from the affidavit- EIGHTY MILLION SIX HUNDRED TWENTY SEVEN
Francisco Ramirez, the handling solicitor, to file the
complaint1 dated 19 January 2004 filed by the Republic required Answer within the period prayed for in his
THOUSAND SIX HUNDRED EIGHTY EIGHT
of the Philippines, represented by Solicitor General (₱1,480,627,688.00) PESOS, representing the reasonable
motion for extension dated 21 May 2003. The plaintiff
Alfredo L. Benipayo, with the Office of the Court rental for the use of the subject property, the interest
was allowed to present her evidence ex parte.
Administrator (OCA), charging Judge Vicente A. Hidalgo thereon at the legal rate, and the opportunity cost at the
with Gross Ignorance of the Law, Manifest Partiality and On 27 August 2003, Judge Hidalgo rendered a rate of three (3%) per cent per annum, commencing July
Conduct Prejudicial to the Interest of the Service relative decision2 in favor of plaintiff Mendoza, the dispositive 1975 continuously up to July 30, 2003, plus, an additional
to Civil Case No. 94075 entitled "Tarcila Laperal Mendoza portion of which reads: interest at the legal rate, commencing from this date
v. The Republic of the Philippines, et al." until the whole amount is paid in full;
WHEREFORE, judgment is hereby rendered:
Facts of the case: 7. Ordering the defendant Republic of the Philippines to
1. Declaring the deed of sale dated July 15, 1975, pay the plaintiff attorney’s fee, in an amount equivalent
On 02 June 1999, Tarcila Laperal Mendoza filed an action annotated at the back of Transfer Certificate of Title No. to FIFTEEN (15%) PER CENT of the amount due to the
for the annulment or declaration of nullity of the title and 118527 as PE:2035/T-118911, as non-existent and/or plaintiff.
deed of sale, reconveyance and/or recovery of ownership fictitious, and, therefore, null and void from the
and possession of a four thousand nine hundred twenty- beginning; With pronouncement as to the costs of the suit.3
four-square meter (4,924.60 sq. m. to be exact) property
2. Declaring that Transfer Certificate of Title No. 118911 Upon receipt by the Office of the Solicitor General of the
against the Republic of the Philippines (in whose name
of the defendant Republic of the Philippines has no basis, judgment by default, the Republic moved for new trial on
the title to the property was transferred and registered)
thereby, making it null and void from beginning; the ground that the gross and inexcusable negligence of
in the Regional Trial Court (RTC) of Manila, and was
Solicitor Ramirez in handling the case does not bind the
docketed as Civil Case No. 94075. The property in 3. Ordering the defendant Register of Deeds for the City
Republic of the Philippines. It argued that it is entitled to
question is located at 1440 Arlegui Street, San Miguel, of Manila to reinstate plaintiff’s Transfer Certificate of
due process of law considering the enormous amount of
Manila. It is also known as the Arlegui Residence  which Title No. 118527;
the alleged obligations involved. It maintained that
housed two (2) Philippine presidents and which now
4. Ordering the defendant Republic of the Philippines to plaintiff’s cause of action has long prescribed and is
holds the Office of the Press Secretary and the News
pay a just compensation in the sum of ONE HUNDRED legally barred by laches, and that the title registered in
Information Bureau.
FORTY THREE MILLION SIX HUNDRED THOUSAN the name of the Republic has become indefeasible.
The case was initially dismissed by the presiding Judge of (₱143,600,000.00) PESOS, plus interest at the legal rate,
The respondent Judge denied the motion for new
the Manila RTC (Branch 35) on the ground of state until the whole amount is paid in full for the acquisition
immunity. A petition for certiorari  was filed with the of the subject property; trial4 and the subsequent motion for
reconsideration5 filed by the Republic. A notice of Republic of the Philippines, Inc. with interest and costs, attorney’s fee, in an amount equivalent to FIFTEEN (15%)
appeal6 dated 27 November 2003 was filed, but the and that you render the same to said Tarcila Laperal aside PERCENT of the amount due to the plaintiff plus costs of
same was denied7 on 17 December 2003 on the ground from your own fees on this execution, and to likewise suit together with all the lawful fees and expenses for the
that it was filed beyond the reglementary period. A return this Writ into this Court within sixty (60) days from service of the Writ of Execution in favor of the above-
certificate of finality8 of judgment was issued by the
the date of receipt hereof with your proceedings named plaintiff.11
endorsed thereon.
Branch Clerk of Court, Atty. Michael B. Robles, on 27 On 07 January 2004, Sheriff Cachero further directed the
November 2003. On 30 December 2003, Sheriff IV Carmelo V. Cachero National Treasurer to cause payment of
directed Eduardo Sergio G. Edeza of the National ₱1,942,576,312.45, thus:
On 10 December 2003, respondent issued an
Treasurer of the Bureau of Treasury to effect the
order9 directing the issuance of a writ of execution. On payment of the sum stated in the decision, thus: TO: Honorable EDUARDO SERGIO G. EDEZA
22 December 2003, a writ of execution10 was issued, National Treasurer of the Philippines, Bureau of Treasury
which reads, thus: TO: Honorable EDUARDO SERGIO G. EDEZA
National Treasurer of the Philippines, Bureau of Treasury Palacio del Gobernador, Intramuros, M a n i l a
TO: THE BRANCH SHERIFF
Palacio del Gobernador, Intramuros S i r:
OF BRANCH 37, RTC, MANILA
Manila Pursuant to the WRIT OF EXECUTION issued by the Hon.
WE COMMAND you to demand that of the goods and VICENTE A. HIDALGO, Judge of the Regional Trial Court,
chattels of THE REPUBLIC OF THE PHILIPPINES you cause G R E E TI N G S: Branch 37, Manila, in the above-entitled case, which was
to be made the sum of ONE HUNDRED FORTY THREE served upon your good office on December 30, 2003,
MILLION SIX HUNDRED THOUSAND PESOS Attached herewith you will find a copy of the WRIT OF
EXECUTION issued by the HON. VICENTE A. HIDALGO, kindly effect and/or cause the payment of the total
(₱143,600,000.00) Philippine Currency, as payment for amount of ONE BILLION NINE HUNDRED FORTY TWO
just compensation plus interest at the legal rate, until the Judge of the Regional Trial Court, Branch 37, Manila, in
the above-entitled case for your ready reference. MILLION FIVE HUNDRED SEVENTY SIX THOUSAND THREE
whole amount is paid in full for the acquisition of the HUNDRED TWELVE PESOS AND FORTY FIVE CENTAVOS
subject property; and the further sum of ONE BILLION By virtue of the said Writ you are hereby directed to (₱1,942,576,312.45), Philippine Currency, made payable
FOUR HUNDRED EIGHTY MILLION SIX HUNDRED TWENTY cause and or effect the payment of the sum of ONE to:
SEVEN THOUSAN SIX HUNDRED EIGHTY EIGHT HUNDRED FORTY THREE MILLION SIX HUNDRED
(₱1,480,627,688.00) PESOS, representing the reasonable THOUSAND PESOS (₱143,600,000.00), Philippine 1. TARCILA I. MENDOZA and/or FORTUNATO I. MENDOZA
rental for the use of the subject property, the interest Currency, as payment for just compensation, plus interest – ₱828,356,119.86 to be deposited with the Land Bank of
thereon at the legal rate, and the opportunity cost at the at the legal rate, until the whole amount is paid in full the Philippines, Main Office, M.H. del Pilar St., Ermita,
rate of three (3%) per cent per annum, commencing July and the further sum of ONE BILLION FOUR HUNDRED Manila under CURRENT ACCOUNT NO. 003402-0014-95;
1975 continuously up to July 30, 2003, plus, an additional EIGHTY MILLION SIX HUNDRED TWENTY SEVEN 2. TARCILA I. MENDOZA and/or APOLONIA C. SOGUILON
interest at the legal rate, commencing from this date THOUSAND SIX HUNDRED EIGHTY EIGHT PESOS – ₱1,065,555,684.78 to be deposited with the Land Bank
until the whole amount is paid in full, the plaintiff (₱1,480,627,688.00) representing the reasonable rental of the Philippines, Main Office, M.H. del Pilar St., Ermita,
attorney’s fee, in an amount equivalent to FIFTEEN (15%) for the use of the subject property, the interest thereon Manila under CURRENT ACCOUNT NO. 003402-0015-17;
PER CENT of the amount due to the plaintiff plus the cost at the legal rate, and the opportunity cost at the rate of
of suit, together with your lawful fees for service of this three (3%) per annum, commencing July 1975 3. CLERK OF COURT, RTC – MANILA – ₱38,851,606.25 to
execution all in money of the Philippines, which the continuously up to July 30, 2003, plus, an additional be deposited with the Land Bank of the Philippines,
plaintiff recovered in our Court, Regional Trial Court of interest at the legal rate, commencing from this date YMCA Branch, Arroceros St., Ermita, Manila under
Manila on the 27th day of August 2003 against the until the whole amount is paid in full, the plaintif’s ACCOUNT NO. 0591-0116-34;
4. CLERK OF COURT, RTC – MANILA – ₱9,712,901.56 to be f. Awarding the amount of two billion pesos The Office of the Solicitor General faults Judge Hidalgo in
deposited with the Land Bank of the Philippines, YMCA (₱2,000,000,000.00) when the property involved is only failing to dismiss the civil case on the grounds of
Branch, Arroceros St., Ermita, Manila under ACCOUNT valued at more than two million pesos (₱2,000,000.00) prescription and laches. The respondent Judge counters
NO. 0591-1744-28.12 and the amount of claim alleged in the complaint is more that such grounds do not apply since the deed of sale
or less three hundred seventy-one million upon which the Republic’s title to the property is based is
The foregoing antecedents begot the instant (₱371,000,000.00) shows that the respondent judge had inexistent and absolutely simulated or fictitious.
administrative complaint13 raising the following been partial in favor of the plaintiff;
allegations against respondent Judge: With respect to the money judgment granted, the
g. The certificate of finality of the judgment by default respondent Judge maintains that the amount awarded to
a. The respondent judge assumed jurisdiction and took was hastily issued on 27 November 2003, the very same the plaintiff was based on testimonies of experts. The
cognizance of the plaintiff’s complaint despite a clear day the Republic filed a notice of appeal; amount of damages given, the respondent explains, is
showing that the action had long prescribed and is "within the four corners of the prayer made in the
already barred by laches. The Republic contends that h. The Republic had until 20 December 2003 to submit its
complaint, i.e., such other relief, just and equitable,
since the complaint showed on its face that the action opposition to the motion for the issuance of the writ of
under the premises."
had prescribed and that the plaintiff’s inaction for a execution, yet the respondent judge denied the
period of almost twenty-four years undoubtedly amounts Republic’s notice of appeal on 17 December 2003 for The Office of the Solicitor General insists that the motion
to laches, the respondent judge was duty bound to being allegedly filed out of time; for new trial should be granted because the gross and
dismiss it motu proprio; inexcusable negligence of Solicitor Ramirez has impaired
i. The Republic filed its opposition to the motion for the
the rights of the Republic, depriving it of its property
b. The money judgment by default rendered by the issuance of a writ of execution on 19 December 2003 and
without due process of law. The respondent Judge
respondent judge in the colossal amount of almost two on the same day, the respondent judge with astonishing
contends that the Office of the Solicitor General is no
billion pesos (₱2,000,000,000.00) is grossly in excess of speed granted the plaintiff’s motion to issue a writ of
ordinary advocate which, due to various constraints and
the claim alleged in the complaint in patent violation of execution.
limitations, can be conceded to commit acts constitutive
Section 3(d), Rule 9 of the 1997 Rules of Civil Procedure The Republic avers that the respondent Judge is liable for of negligence, mistake or lack of competence. He notes
and grossly disproportionate to the total amount of these unjustified and irregular acts which constitute that all pleadings bear at least three (3) signatures - that
docket fees paid; gross ignorance of the law, manifest partiality and of the handling solicitor, the assistant solicitor general
c. The respondent judge violated the Constitution and conduct prejudicial to the best interest of the service. and the solicitor general, showing that pleadings go
the fundamental rule that government funds are exempt through the rung of the ladder of authority ensuring their
On 12 February 2004, OCA required14 respondent Judge conformity to existing jurisprudence and compliance with
from execution or garnishment; to submit his comment within ten (10) days from receipt. procedural rules.
d. The respondent judge ordered the Republic to pay the
In his COMMENT15 dated 15 March 2004, respondent It is also contended by the Republic that the certificate of
plaintiff’s attorney’s fees with pronouncement as to the
Judge Vicente A. Hidalgo claims that the instant finality of the judgment by default was hastily issued,
costs of the suit in violation of the clear provision of
administrative complaint was instituted against him in showing the manifest partiality of the respondent Judge
Section 1, Rule 142 which provides that no costs shall be
order to "hide from view a monstrous fiasco." The for the plaintiff. The respondent Judge avers that upon
allowed against the Republic of the Philippines unless
respondent Judge maintains that the Office of the the denial of the motion for new trial which the Office of
otherwise provided by law;
Solicitor General, having failed to fulfil its duty as counsel the Solicitor General received on 09 October 2003, the
e. The respondent judge condemned the Republic to for the defendant, is trying to "escape criticism and Republic had only one (1) day left or until 10 October
suffer the obligation of almost two billion responsibility for bungling the case by the simple 2003 to file its appeal. Instead of filing its appeal, it filed a
(₱2,000,000,000.00) in violation of its right to due expedient smokescreen of making the respondent a motion for reconsideration on 24 October 2003 which
process; convenient scapegoat for its ineptitude and inefficiency." the respondent denied in an order dated 25 November
2003. This is contrary to the provision in the Rules of for allegedly bungling the case, the Republic counters In declaring the government answerable to the attorney’s
Court that "(a)n order denying a motion for new trial or that the respondent himself cannot justify his actions by fees of the plaintiff and other costs of the suit, the
reconsideration is not appealable, the remedy being an hiding under the cloak of speedy disposition of the case respondent utterly disregarded the well-established rule
appeal from the judgment or final order" (Sec. 9, Rule 37, as prescribed by the Court. that costs of suit are not recoverable against the
1997 Rules of Civil Procedure). The respondent Judge government (Section 1, Rule 142, Rules of Court). As
On 14 April 2005, the OCA issued its
argues that the filing of the notice of appeal on 27 early as 15 November 1918, we ruled in the case of Hong
November 2003, forty-eight (48) days from the last day recommendation,17 thus: Kong and Shanghai Banking Corporation v.
to perfect appeal, was made too late because the In view of the foregoing, we respectfully submit for the Rafferty19 that no costs shall be allowed against the
decision had already become final and executory. consideration of the Honorable Court the following government of the Philippine Islands where the
recommendation: government is the unsuccessful party. This was reiterated
In its REPLY16 dated 03 March 2004, the Republic
in the case of Philippines Veterans Affairs Office v.
reiterates its charges of gross ignorance of the law, 1. That the instant administrative complaint be RE –
manifest partiality, violation of due process and conduct DOCKETED as a regular administrative matter; Anover20 and The Philippine Veterans Affairs Office v.
prejudicial to the best interest of the service against Tamayo,21 when we ruled that court costs are not
2. That Judge Vicente A. Hidalgo, Presiding Judge, recoverable from a government agency.
Judge Hidalgo. The Republic insists that the respondent
Regional Trial Court (Branch 37), Manila be found
Judge deserves to be dismissed from the service for Upon finality of the decision dated 27 August 2003,
administratively liable for GROSS IGNORANCE OF THE
being guilty of the foregoing offenses. respondent Judge directed the issuance of the writ of
LAW OR PROCEDURE under Sec. 8 (9), Rule 140 of the
The Republic asserts that the motion for new trial was Rules of Court; and execution and subsequently issued the writ of execution
filed to rectify the grossly negligent act of the handling on 22 December 2003.
3. That Judge Hidalgo be FINED in the amount of forty
solicitor which gravely prejudiced its interest. It maintains It is settled that when the State gives its consent to be
thousand pesos (₱40,000.00) and be WARNED that a
that the Judge violated its right to due process when he sued, it does not thereby necessarily consent to an
repetition of the same or similar acts will be dealt with
proceeded to hold it liable for the omissions and unrestrained execution against it. Tersely put, when the
more severely.
negligence of a lawyer who had ceased to be the State waives its immunity, all it does, in effect, is to give
authorized agent of the government. The recommendation of the OCA is well-taken. the other party an opportunity to prove, if it can, that the
It is also contended that the respondent Judge violated In the present case, respondent Judge patently state has a liability. In Republic v. Villasor22 this Court, in
the Constitution and the fundamental rule that committed two inexcusable procedural errors – the nullifying the issuance of an alias writ of execution
government funds are exempt from execution or pronouncement of costs against the government and the directed against the funds of the Armed Forces of the
garnishment when he caused the issuance of the writ of subsequent issuance of the writ of execution, in violation Philippines to satisfy a final and executory judgment, has
execution against the Republic. It is likewise asserted that of settled rules and jurisprudence. explained, thus—
in ordering the Republic to pay the attorney’s fees of . . . The universal rule that where the State gives its
In the decision dated 27 August 2003, respondent Judge
plaintiff and the cost of the suit, the respondent violated consent to be sued by private parties either by general or
declared the Republic liable for payment of attorney’s
the clear provision of Section 1, Rule 142 of the Rules of special law, it may limit claimant’s action "only up to the
fees and cost of suit, pertinent portion of which reads:
Court heretofore cited. In these two issues, the Republic completion of proceedings anterior to the stage of
observes that the respondent is conspicuously silent 7. Ordering the defendant Republic of the Philippines to
execution" and that the power of the Courts ends when
because he cannot offer any defense, as his actions are pay the plaintiff attorney’s fee, in an amount equivalent
the judgment is rendered, since government funds and
glaringly illegal. to FIFTEEN (15%) PER CENT of the amount due to the
properties may not be seized under writs of execution or
plaintiff.
Anent the accusation of the respondent that he is being garnishment to satisfy such judgments, is based on
used by the Office of the Solicitor General as a scapegoat With pronouncement as to the costs of the suit.18 obvious considerations of public policy. Disbursements of
public funds must be covered by the correspondent the Code of Judicial Conduct, should be the embodiment 2. Suspension from office without salary and other
appropriation as required by law. The functions and of competence, integrity, and independence. benefits for more than three (3) but not exceeding six (6)
public services rendered by the State cannot be allowed Competence is a mark of a good judge. When a judge months; or
to paralyzed or disrupted by the diversion of public funds displays an utter lack of familiarity with the rules, he
3. A fine of more than ₱20,000.00 but not exceeding
from their legitimate and specific objects, as erodes the public’s confidence in the competence of our
₱40,000.00.
appropriated by law.23 courts.27 It is highly imperative that judges be
conversant with the law and basic legal Taking into consideration the length of
In Administrative Circular No. 10-2000 dated 25 October
principles.28 Basic legal procedures must be at the palm service30 rendered by respondent Judge and following
2000, all judges of lower courts were advised to exercise
utmost caution, prudence and judiciousness in the of a judge’s hands.29 our rulings in Gamas v. Oco,31 and Sule v. Biteng,32 a
issuance of writs of execution to satisfy money fine of ₱20,000.00 is justified.
In the case at bar, respondent Judge not only failed to
judgments against government agencies and local perform his duties in accordance with the Rules, but he The other charges against Judge Hidalgo and the issues
government units. Judges, thus, cannot indiscriminately also acted wilfully and in gross disregard of the law and arising therefrom are judicial matters not subject to
issue writs of execution against the government to controlling jurisprudence. He was ignorant of the basic administrative scrutiny. The Republic has, in fact, filed a
enforce money judgments. and simple procedural rules by issuing the writ of petition for certiorari on 30 January 2004 against the
It is clear that respondent Judge ought to be sanctioned execution and pronouncing the costs of suit against the respondent, docketed as G.R. No. 161657, and remains
for his failure to properly apply the court procedure. As government. Verily, respondent Judge’s actions visibly pending before the Third Division. The present
can be seen, the law involved is simple and elementary. indicate his lack of sufficient grasp of the law. administrative case is without prejudice to any other
When the law is sufficiently basic, a judge owes it to his action which may be taken on said petition.
For issuing the writ of execution and pronouncing the
office to simply apply it, and anything less than that costs of the suit against the government, we deem that All told, this Court once again seizes the moment to
would be constitutive of gross ignorance of the law. In the respondent Judge is liable for gross ignorance of the remind judges to keep abreast of the rules and recent
short, when the law is so elementary, not to be aware of law or procedure under Rule 140 of the Rules of Court. pronouncements of this Court, so they may evolve into
it constitutes gross ignorance of the law.24 When the more effective dispensers of justice -- magistrates of the
Under Rule 140, Section 8, of the Rules of Court, as
inefficiency springs from a failure to consider so basic law in the truest sense of the word.33
and elementary a rule, a law or principle in the discharge amended by A.M. No. 01-8-10 SC, gross ignorance of the
of his duties, a judge is either too incompetent and law or procedure is classified as a serious charge. As to WHEREFORE, the Court finds respondent Judge Vicente
undeserving of the position and title he holds or is too the penalty imposed, Section 11 of the same Rule A. Hidalgo administratively liable for gross ignorance of
vicious that the oversight or omission was deliberately provides: the law and is accordingly fined the amount of Twenty
done in bad faith and in grave abuse of judicial Thousand (₱20,000.00) Pesos with a stern warning that a
SEC. 11. Sanctions. - A. If the respondent is guilty of a
repetition of the same or similar act will be dealt with
authority.25 serious charge, any of the following sanctions may be
more severely.
imposed:
Canon 4 of the Canon of Judicial Ethics requires that a
SO ORDERED.
judge should be studious of the principles of law; while 1. Dismissal from the service, forfeiture of all or part of
Canon 18 mandates that he should administer his office the benefits as the Court may determine, and MINITA V. CHICO-NAZARIO
with due regard to the integrity of the system of the law disqualification from reinstatement or appointment to Associate Justice
itself, remembering that he is not a depositary of any public office, including government-owned or
WE CONCUR:
arbitrary power, but a judge under the sanction of controlled corporations: Provided, however, that the
law.26 The maxim "ignorance of the law excuses no one" forfeiture of benefits shall in no case include accrued
has special application to judges, who, under Rule 1.01 of leave credits;
 REYNATO S. PUNO 16 Rollo, pp. 132-149. 28 Borja-Manzano v. Sanchez, A.M. No. MTJ-00-
Associate Justice 1329, 08 March 2001, 354 SCRA 1.
Chairman 17 Rollo, pp. 151-157.
29 Pesayco v. Layague, A.M. No. RTJ-04-1889,
MA. ALICIA AUSTRIA-MARTINEZ ROMEO J. CALLEJO, SR.18 Rollo, pp. 55-56. 22 December 2004, 447 SCRA 450.
Associate Justice Associate Justice 19 39 Phil. 145 (1918).
30 28 years.
DANTE O. TINGA 20 G.R. No. L-39835, 27 October 1983, 125 31 A.M. No. MTJ-99-1231, 17 March 2004, 425
Associate Justice SCRA 354. SCRA 588. In this case, respondent Judge was
21 G.R. No. L-74322, 29 July 1988, 163 SCRA found guilty of gross ignorance of the law for
776. failure to comply with the requirements of
Section 1(a) of Rule 116, by failing to furnish
Footnotes 22 G.R. No. L-30671, 28 November 1973, 54 complainants therein a copy of the information
SCRA 83. with the list of the witnesses and was meted a
1 Rollo, pp. 1-28.
fine of ₱20,000.00.
23 See also Commissioner of Public Highways v.
2 Rollo, pp. 56-57; Decision dated 27 August
2003.
San Diego, G.R. No. L-30098, 18 February 1970, 32 A.M. No. MTJ-95-1018, 18 April 1995, 243
31 SCRA 616, citing among others the following SCRA 524. In this case, respondent Judge was
3 Rollo, pp. 55-56. decisions: Meritt v. Government of the found guilty of gross ignorance of the law when
Philippine Islands, 34 Phil. 311 (1916); Visayan he granted bail solely on account of the
4 Rollo, pp. 77-84. Refining Co. v. Camus and Paredes, 40 Phil. 550 voluntary surrender of the accused and was
5 Rollo, p. 85. (1919); Director of Commerce and Industry v. meted a fine of ₱20,000.00.
Concepcion, 43 Phil. 384 (1922); Belleng v.
6 Rollo, pp. 86-87. Republic, G.R. No. L-19856, 16 September 1963, 33 Comia v. Antona, A.M. No. RTJ-99-1518, 14
9 SCRA 6; Republic v. Palacio, G.R. No. L-20322, August 2000, 337 SCRA 656.
7 Rollo, pp. 91-92. 29 May 1968, 23 SCRA 899.
8 Rollo, p. 89. 24 Canas v. Castigador, G.R. No. 139844, 15
9 Rollo, p. 93. December 2000, 348 SCRA 425.

10 Rollo, p. 94. 25 Almojuela, Jr. v. Ringor, A.M. No. MTJ-04-

1521, 27 July 2004, 435 SCRA 261; Lim v. Fineza,
11 Rollo, p. 95. A.M. No. RTJ-02-1705, 05 May 2003, 402 SCRA
534.
12 Rollo, p. 96.
26 Jason v. Ygaña, A.M. RTJ-00-1543, 04 August
13 Rollo, pp. 1-28.
2000, 337 SCRA 264.
14 Rollo, p. 98.
27 Guillen v. Canon, A.M. No. MTJ-01-1382, 41
15 Rollo, pp. 102-119. January 2002, 373 SCRA 70.