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:

Administrative Complaints and Charges

• Complainant: Atty. Norlinda R. Amante-Descallar, Clerk of Court of RTC Branch 18, Pagadian City.
• Seven administrative complaints were filed against Judge Reinerio Abraham B. Ramas.
• The charges included gross ignorance of the law, gross negligence, and violation of the Code of Judicial Conduct.
• Specific allegations involved:
• Misinterpretation of Rule 39 in Civil Case No. 3412 regarding the computation of a five-year period.
• Approval of plea bargaining arrangements in criminal cases (People v. Cebedo, People v. Dumpit, and others) allegedly contrary to procedural rules and statutory prohibitions.
• Errors related to the issuance and subsequent quashing of search warrants, including discrepancies in the names of the accused.
• Dismissal of criminal cases (e.g., People v. Lopez and People v. Fernandez) in manners alleged to be premature or lacking due process.

Specific Cases and Alleged Judicial Errors

• Misc. No. 2820
• Involved the order granting execution of the prevailing party in a civil case.
• Complainant argued the error pertained to the incorrect reckoning of the five-year period from counsel’s receipt rather than the entry of judgment.
• Misc. No. 2821
• Concerned plea bargaining in Criminal Cases Nos. 5601-2000 and 5602-2000 (People v. Cebedo).
• Allegations centered on noncompliance with the procedural requirements of Rule 116, Section 2 of R.A. No. 8493, and Supreme Court Circular No. 38-98.
• Misc. No. 2824
• Examined the validity of plea bargaining in Criminal Case Nos. 5760-2K, 5761-2K, and 5762-2K (People v. Dumpit).
• Issues raised included:
• Approval of the plea bargaining agreement which led to the dismissal of some cases.
• A separate allegation of gross negligence in the issuance of Search Warrant No. 40-03.
• Misc. No. 2825
• Involved the dismissal of Criminal Case No. 8149-2K6 (People v. Lopez).
• The complaint asserted that the court dismissed the case for lack of probable cause before the 10-day period allowed for the prosecution to file a comment, thereby violating due process.
• Misc. No. 2860
• Related to a search conducted under Search Warrant No. 87-04 in Criminal Case No. 7235-2K4.
• Complainant alleged that an error in the motion—inadvertently asking to quash another warrant—was reproduced in the court’s resolution, demonstrating a lack of proper review.
• Misc. No. 2861
• Concerned the provisional dismissal of Criminal Case No. 6994-2K3 (People v. Fernandez) due to the prosecution’s failure to present a laboratory technician.
• Complainant argued that dismissal based on this ground was improper since other evidence was already presented.

Evaluation by the Office of the Court Administrator (OCA)

• The OCA’s report found respondent Judge Ramas guilty of gross ignorance of the law in Misc. No. 2821 and Misc. No. 2824.
• Other complaints (Misc. Nos. 2820, 2825, 2860, 2861, and 2887) were recommended for dismissal on the ground that they related primarily to matters of judicial discretion.
• The report also noted a prior administrative complaint (RTJ-06-2015) where the same respondent was found guilty of simple misconduct, with lesser sanctions imposed.

Circumstances Surrounding the Issuance of Orders and Judicial Exercise of Discretion

• Respondent Judge Ramas defended his decisions by asserting that:
• In cases where nothing was contested by the prosecution or the accused, his orders became final and executory as a matter of law.
• His rulings were the exercise of judicial discretion, even if later questionably interpreted.
• The dispute also touched upon whether judicial errors committed in good faith qualify for administrative sanctions unless accompanied by bad faith or dishonesty.
• The crux of the controversy often centered on the clear statutory provisions in R.A. No. 6425 regarding plea bargaining and the interpretation of procedural timelines.

Issue:

Whether Judge Ramas’s issuance of orders under the various complaints amounted to gross ignorance of the law.

• Did the interpretation of Rule 39 (re: computation of the five-year period) in the civil case amount to an error warranting administrative liability?

Whether the approval of plea bargaining agreements in criminal cases violated:

• The plea bargaining restrictions under Sections 15, 16, and 20-A of R.A. No. 6425 (as amended), and
• The procedural mandates of the Rules on Criminal Procedure and applicable Supreme Court circulars.
• Whether the issuance, signing, and subsequent quashing of search warrants (in Misc. Nos. 2824 and 2860) demonstrate gross negligence on the part of the judge.
• Whether dismissals of criminal cases before the expiration of the prescribed period for the prosecution to comment (as seen in Misc. No. 2825) or based solely on evidentiary omissions (as in Misc. No. 2861) constitute a violation of due process.
• Whether the alleged errors, even if present, were committed in good faith or were tainted by bad faith, malice, fraud, or dishonesty such that they justify administrative sanctions.
• Whether judicial errors or lapses—when conducted within the ambit of the judge’s discretion—should be remedied through judicial rather than administrative proceedings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)