Facts:

The case involves 3-D Industries, Inc. and Smartnet Philippines, Inc. (collectively referred to as the complainants) against Court of Appeals Associate Justices Vicente Q. Roxas and Juan Q. Enriquez, Jr. The complaint was initiated on May 13, 2005, and it was referred to this Court’s Office of the Court Administrator by the Office of the Ombudsman. The heart of the matter is centered around allegations of violations of the Anti-Graft and Corrupt Practices Act (R.A. 3019, as amended) committed by the respondents in their judicial capacity.

The circumstances stem from a corporate dispute involving Northern Islands Co., Inc. (NICI). Gilbert Guy, representing Smartnet, is the son of Francisco and Simny Guy, who founded NICI. Accusations arose when the spouses accused Gilbert of mismanaging Lincoln Continental Development Corp., a holding company that owned shares in NICI. The spouses subsequently transferred NICI shares to their three daughters. In March 2004, Lincoln Continental f

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Facts:

Background of the Dispute

• Complainants 3-D Industries, Inc. and Smartnet Philippines, Inc.—represented by Gilbert Guy—filed an administrative complaint citing that the Court of Appeals (CA) Justices Vicente Q. Roxas and Juan Q. Enriquez, Jr. violated Section 3(e) of the Anti-Graft and Corrupt Practices Act (R.A. 3019).
• The controversy stemmed from a series of actions involving the management and control of Northern Islands Co., Inc. (NICI), a company engaged in the manufacture, distribution, and sale of home appliances bearing the “3-D” trademark.
• The dispute originated with the Guy family, who, after finding that their son Gilbert had been dissipating the assets of Lincoln Continental Development Corporation, transferred 50% of NICI’s shares to Gilbert’s three sisters to enable their participation in managing the company.

Sequence of Judicial and Extrajudicial Proceedings

• On March 18, 2004, Lincoln Continental filed a complaint at the Regional Trial Court (RTC) of Manila against NICI and the Guy family seeking annulment of the share transfer, restoration of NICI’s management to Gilbert, and issuance of a Temporary Restraining Order (TRO) and a writ of preliminary mandatory injunction to bar the sisters from exercising ownership rights over the disputed shares.
• After challenges regarding judicial impartiality—resulting in a re-raffling of the case from RTC Branch 24 to Branch 46—the Manila RTC Branch 46 issued on June 15, 2004, a TRO and later, on October 13, 2004, a writ of preliminary mandatory injunction favoring Lincoln Continental.
• NICI and the Guy family then sought relief by filing a new petition for certiorari (docketed as CA-G.R. SP No. 87104) before the CA’s Eighth Division, requesting the nullification of the RTC TRO and injunction to restore the status quo ante.
• On October 28, 2004, the CA’s Eighth Division responded by issuing a TRO enjoining the implementation of the RTC writ, followed by NICI and the Guy family’s filing of an Urgent Omnibus Motion on November 2, 2004, which resulted in a break-open order executed on November 4, 2004.
• Additional litigation followed:
• Smartnet, an occupant of the NICI premises, filed a forcible entry complaint with the Metropolitan Trial Court on December 16, 2004.
• On December 22, 2004, the CA-Eighth Division issued a writ of preliminary injunction pursuant to NICI and the Guy family’s new petition.
• Gilbert later initiated a replevin action on behalf of 3-D before the RTC of Pasig City, resulting in a writ issued on January 18, 2005.
• In response, NICI and the Guy family filed a Supplemental Petition for Certiorari with an urgent motion for a writ of preliminary injunction on January 20, 2005, and later a Second Supplemental Petition for Certiorari and Prohibition on April 15, 2005, which expanded the range of relief and impleaded additional respondents including Smartnet.

Allegations of Judicial Misconduct

• Complainants charged that by admitting the Supplemental Petition (Resolution dated January 24, 2005) and the Second Supplemental Petition (Resolution dated April 26, 2005)
• The CA justices allegedly granted unwarranted benefits and advantages to NICI and the Guy family.
• They exhibited manifest partiality, evident bad faith, or gross inexcusable negligence in the discharge of their judicial functions.
• It was further contended that the assignment of the “supplemental” petitions to the Eighth Division was intentionally manipulated to avoid less sympathetic divisions, thereby assuring favorable treatment.
• Complainants also argued that the conclusory and expedient ruling amounted to a “lame pretext” for dispensing injunctive relief, noting that the properties involved were not under custodia legis and that there was no factual basis to establish that 3-D operated merely as an alter ego or dummy of Gilbert.

Procedural Developments and Administrative Response

• The administrative complaint, verified on May 13, 2005, was referred by the Office of the Ombudsman to the Supreme Court’s Office of the Court Administrator for investigation.
• On July 28, 2009, the Court required respondent Justice Enriquez to comment on the complaint and explain why disciplinary sanctions should not be imposed.
• Justice Enriquez, in his Comment dated September 16, 2009, contended that the resolution his division issued had been previously upheld by this Court and that his participation was within the proper exercise of judicial function.
• Complainants, in their reply dated December 4, 2009, stressed that the earlier decision was silent on expanding the writ’s coverage and that the rushed nature of the supplemental petitions’ admission was improper.

Issue:

Whether the issuance or admission of the Supplemental Petitions for Certiorari (including the Second Supplemental Petition) by the CA justices amounted to:

• A violation of Section 3(e) of R.A. No. 3019, by giving any private party (NICI and the Guy family) an unwarranted benefit or advantage.
• Acts committed with manifest partiality, evident bad faith, or gross inexcusable negligence in the discharge of their official judicial functions.

• Whether the “assignment” of the supplemental petitions to the Eighth Division was a deliberate maneuver to secure favorable judicial outcomes by circumventing divisions that might not be sympathetic to the Guy family’s interests.

• Whether the conclusory and expedited rulings, which extended the scope of injunctive relief despite the absence of properties under custodia legis and without establishing that 3-D acted as an alter ego of Gilbert, constitute sufficient grounds for administrative liability.

• Whether procedural errors or judicial misjudgments—specifically in admitting the additional parties—automatically render a judge administratively liable under the stringent requirements of the Anti-Graft and Corrupt Practices Act.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)