Facts:

The case involves an administrative complaint filed by Lolita Andrada against Hon. Emmanuel G. Banzon, the Presiding Judge of the Municipal Trial Court (MTC) in Mariveles, Bataan. The complaint was lodged on November 25, 2008, alleging grave misconduct, grave abuse of authority, oppression, and gross ignorance of the Rules on Contempt under Rule 71 of the Rules of Court. The background of the case dates back to June 22, 1999, when Nestor Soria initiated an ejectment case against Lolita Andrada and her husband, Faustino Andrada, which was assigned to Judge Banzon. After summary proceedings, the court ruled in favor of Soria, ordering the Andradas to vacate the premises. This decision was upheld by the Regional Trial Court, Branch IV, in Balanga, Bataan. Following the finality of the judgment, the case records were sent back to the MTC for execution. The first writ of execution issued on January 16, 2001, was returned unsatisfied due to the Andradas' refusal to vacate. Subs...

Facts:

Background of the Case:

• Lolita Andrada filed an administrative complaint against Hon. Emmanuel G. Banzon, Presiding Judge of the Municipal Trial Court (MTC) in Mariveles, Bataan, alleging grave misconduct, grave abuse of authority, oppression, and gross ignorance of the Rules on Contempt under Rule 71 of the Rules of Court.

Ejectment Case:

• On June 22, 1999, Nestor Soria filed an ejectment case (Civil Case No. 99-830) against Lolita Andrada and her spouse, Faustino Andrada. The case was raffled to Judge Banzon’s sala.
• After summary proceedings, the MTC ruled in favor of Soria, ordering the Andradas to vacate the premises. This decision was affirmed by the Regional Trial Court (RTC) in Balanga, Bataan.

Execution of Judgment:

• The first writ of execution (January 16, 2001) was returned unsatisfied as the Andradas refused to vacate.
• An alias writ of execution was issued on August 6, 2001. While the second alias writ was executed, the Andradas erected temporary structures blocking Soria’s access to the premises.

Contempt Proceedings:

• Soria filed a "Motion to Cite Defendants in Contempt."
• Judge Banzon issued an Order on June 5, 2002, granting the motion but did not cite the Andradas in contempt. Instead, he gave them five (5) days to vacate.

Appeal Attempt:

• Lolita Andrada filed a notice of appeal, which Judge Banzon refused to accept, stating that the June 5, 2002 Order was interlocutory and not appealable.

Administrative Complaint:

• Lolita Andrada filed the instant administrative complaint, accusing Judge Banzon of grave abuse of authority, oppression, and gross ignorance of the Rules on Contempt.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. On Grave Abuse of Authority and Oppression:

   • To hold a judge liable for grave abuse of authority or oppression, there must be evidence of cavalier or arrogant behavior, or the use of intemperate and harsh language. Complainant failed to provide substantial evidence to prove such conduct by Judge Banzon.
   • Judge Banzon merely informed Lolita Andrada that the June 5, 2002 Order was interlocutory and not appealable. This action does not constitute grave abuse of authority or oppression.

2. On Gross Ignorance of the Law:

   • Gross ignorance of the law requires more than an erroneous ruling; it must be shown that the judge acted with bad faith, fraud, dishonesty, or corruption. There was no evidence that Judge Banzon acted with malice or corrupt motives.
   • The June 5, 2002 Order was indeed interlocutory, and a notice of appeal was not the proper remedy. The correct remedy would have been a petition for certiorari under Rule 65 of the Rules of Court.

3. On the Proper Remedy for Interlocutory Orders:

   • The Court clarified that interlocutory orders, which do not touch on the merits of the case or end the proceedings, cannot be appealed. The proper remedy is a petition for certiorari under Rule 65, not a notice of appeal.

4. On Judicial Accountability:

   • Judges cannot be held administratively liable for every erroneous ruling or decision unless there is clear evidence of bad faith, fraud, or deliberate intent to do injustice. The Court emphasized the need to protect judges from unfounded suits that disrupt the administration of justice.

Conclusion:

• The Court upheld the findings of the Investigating Justice and dismissed the administrative complaint against Judge Banzon for lack of substantial evidence. The decision reinforces the principle that judges should not be harassed by baseless complaints and that their rulings, even if erroneous, do not automatically warrant administrative sanctions unless accompanied by malice or corruption.