Facts:

The case involves Atty. Norlinda R. Amante-Descallar as the complainant against Judge Reinerio Abraham B. Ramas, who presides over the Regional Trial Court, Branch 18, in Pagadian City. The administrative complaints were filed on various dates, with the primary complaint being lodged on March 20, 2009. Atty. Amante-Descallar, who served as the Clerk of Court, accused Judge Ramas of gross ignorance of the law, gross negligence, and violations of the Code of Judicial Conduct.

The complaints stemmed from several incidents, including the judge's handling of Civil Case No. 3412, where he erroneously calculated the five-year period for execution from the counsel's receipt of the Entry of Judgment instead of the date of entry itself, as mandated by Section 6 of Rule 39 of the Rules of Court. In another instance, during the plea bargaining process in Criminal Case Nos. 5601-2000 and 5602-2000, Judge Ramas approved an agreement that was allegedly contrary to the provisions ...

Facts:

1. Misc. No. 2820 (Gross Ignorance of the Law - Civil Case No. 3412)

   • Complainant Atty. Norlinda R. Amante-Descallar accused Judge Reinerio Abraham B. Ramas of gross ignorance of the law for granting a motion for execution in Civil Case No. 3412.
   • The judge allegedly erred by counting the five-year period for execution under Section 6, Rule 39 from the counsel's receipt of the Entry of Judgment, instead of from the date of entry of judgment.
   • Complainant argued that the judge’s action violated Rule 3.02, Canon 3 of the Code of Judicial Conduct.

2. Misc. No. 2821 (Gross Ignorance of the Law - Criminal Case Nos. 5601-2000 and 5602-2000)

   • Complainant alleged that the judge improperly approved a plea bargaining agreement in Criminal Case Nos. 5601-2000 and 5602-2000 ("People v. Cebedo").
   • The defense offered to plead guilty to possession of shabu (Crim. Case No. 5602-2000) in exchange for the dismissal of the charge for selling shabu (Crim. Case No. 5601-2000).
   • Complainant argued that the plea bargaining violated Section 2 of Rule 116, Sections 2 and 3 of R.A. No. 8493, and Supreme Court Circular No. 38-98, as it was unclear whether the offended party consented and whether the prosecutor had proper authority.

3. Misc. No. 2824 (Gross Ignorance of the Law and Gross Negligence - Criminal Case Nos. 5760-2K, 5761-2K, 5762-2K)

   • Complainant questioned the validity of the plea bargaining in Criminal Case Nos. 5760-2K, 5761-2K, and 5762-2K ("People v. Dumpit").
   • The judge approved the plea bargaining agreement, dismissed two cases, and found the accused guilty in one case. The accused was later released on recognizance.
   • Complainant also accused the judge of gross negligence in issuing Search Warrant No. 40-03, which contained an error in the name of the accused, rendering it void.

4. Misc. No. 2825 (Gross Ignorance of the Law - Criminal Case No. 8149-2K6)

   • Complainant alleged that the judge dismissed Criminal Case No. 8149-2K6 ("People v. Lopez") for lack of probable cause without giving the prosecution the full 10-day period to file a comment, violating due process.

5. Misc. No. 2860 (Gross Ignorance of the Law - Criminal Case No. 7235-2K4)

   • Complainant accused the judge of gross ignorance for issuing Search Warrant No. 87-04 and later invalidating it due to non-compliance with legal requisites.
   • The judge also allegedly failed to notice an error in the motion to quash the search warrant, which asked for the quashal of a different search warrant.

6. Misc. No. 2861 (Gross Ignorance of the Law - Criminal Case No. 6994-2K3)

   • Complainant alleged that the judge provisionally dismissed Criminal Case No. 6994-2K3 ("People v. Fernandez") for the prosecution’s failure to present a laboratory technician, despite having presented other witnesses.
   • Complainant argued that the judge should have passed upon the testimonies of other witnesses before dismissing the case.

7. Misc. No. 2887 (Gross Ignorance of the Law - Criminal Cases Involving Raup Ibrahim and Vivian Duerme)

   • Complainant alleged that the judge dismissed three criminal cases involving Raup Ibrahim and Vivian Duerme without giving the prosecution the full 10-day period to file a comment on the motions to suppress evidence and quash information.

Issue:

1. Whether Judge Reinerio Abraham B. Ramas is administratively liable for gross ignorance of the law and gross negligence in the following cases:

   • Misc. No. 2820 (Civil Case No. 3412)
   • Misc. No. 2821 (Criminal Case Nos. 5601-2000 and 5602-2000)
   • Misc. No. 2824 (Criminal Case Nos. 5760-2K, 5761-2K, 5762-2K)
   • Misc. No. 2825 (Criminal Case No. 8149-2K6)
   • Misc. No. 2860 (Criminal Case No. 7235-2K4)
   • Misc. No. 2861 (Criminal Case No. 6994-2K3)
   • Misc. No. 2887 (Criminal Cases Involving Raup Ibrahim and Vivian Duerme)

2. Whether the judge’s actions in these cases violated the Code of Judicial Conduct and other relevant laws.

Ruling:

1. Misc. No. 2820

   • The Court dismissed the charge for lack of merit. The judge’s interpretation of Section 6, Rule 39 did not automatically render him administratively liable. There was no showing of bad faith, malice, or dishonesty.

2. Misc. No. 2821 and Misc. No. 2824

   • The Court disagreed with the Office of the Court Administrator (OCA) and found that the judge’s approval of plea bargaining agreements did not amount to gross ignorance of the law. The prohibition on plea bargaining under R.A. No. 6425 was not absolute, and the judge’s discretion was within his judicial functions.

3. Misc. No. 2825 and Misc. No. 2887

   • The Court found the judge guilty of gross ignorance of the law for violating due process by dismissing cases without giving the prosecution the full period to file comments. The judge was suspended for six months without salary and other benefits.

4. Misc. No. 2860 and Misc. No. 2824 (Negligence)

   • The Court found the judge guilty of negligence for failing to scrutinize documents before signing them. He was fined P5,000.00.

5. Misc. No. 2861

   • The Court dismissed the charge for lack of merit. The provisional dismissal of the case was within the judge’s discretion.

Ratio:

1. Judicial Errors and Administrative Liability

   • Not every error committed by a judge in the exercise of judicial functions renders him administratively liable. Errors must be accompanied by bad faith, malice, or dishonesty to warrant disciplinary action.

2. Plea Bargaining

   • Plea bargaining is within the discretion of the trial court, subject to statutory and procedural requirements. The judge’s approval of plea bargaining agreements in Misc. No. 2821 and Misc. No. 2824 did not amount to gross ignorance of the law, as the prohibition under R.A. No. 6425 was not absolute.

3. Due Process Violations

   • The judge’s failure to give the prosecution the full period to file comments in Misc. No. 2825 and Misc. No. 2887 constituted a blatant disregard of due process, warranting administrative sanctions.

4. Negligence

   • Judges are expected to exercise diligence in scrutinizing documents before signing them. The judge’s failure to do so in Misc. No. 2860 and Misc. No. 2824 constituted negligence.

5. Remedies for Judicial Errors

   • Errors in judicial decisions should be corrected through judicial remedies, such as appeals or petitions for certiorari, rather than administrative complaints, unless there is evidence of bad faith, malice, or dishonesty.

Conclusion:

The Court found Judge Reinerio Abraham B. Ramas guilty of gross ignorance of the law in Misc. No. 2825 and Misc. No. 2887, suspending him for six months without salary and other benefits. He was also found guilty of negligence in Misc. No. 2860 and Misc. No. 2824, fined P5,000.00, and sternly warned. The charges in Misc. No. 2820, Misc. No. 2821, and Misc. No. 2861 were dismissed for lack of merit.