Facts:

The case in question involves Rafael Aquino, Sr. and Renato V. Aquino as complainants against Judge Julito B. Valenciano, who served as the Presiding Judge of the 6th Municipal Circuit Trial Court in Polangui-Libon, Albay. The events originated on October 19, 1992, when Renato V. Aquino filed an amended complaint for robbery against several defendants, including Romeo Matias, Jim Boquiron, and Aniano Lascano. The complainant claimed that, except for Lascano, the said individuals conspired to unlawfully take ninety-six (96) fish cages belonging to him through violence and intimidation. A search and seizure order was subsequently issued by Judge Jacinto J. Penaflor, enabling law enforcement authorities to confiscate the fish cages at Lake Bato.

However, on October 21, 1992, Respondent Judge Julito B. Valenciano granted an urgent ex-parte petition from Romeo Matias for a restraining order while a grave coercion case was pending against Renato V. Aquino. This restraining order direc

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Facts:

Parties and Underlying Actions

• Complainants:

1.1. Rafael Aquino, Sr. 1.2. Renato V. Aquino 2.1. Judge Julito B. Valenciano, Presiding Judge, 6th Municipal Circuit Trial Court, Polangui-Libon, Albay 3.1. Complainants charged the respondent judge with gross ignorance of the law, abuse of authority, bias, and malicious interference with judicial proceedings. 3.2. The charges emanated from the issuance of a restraining order and other discretionary acts affecting criminal cases already under judicial process.

Factual Background and Procedural History

• The Robbery Complaint and Search & Seizure Order

1.1. On October 19, 1992, Renato V. Aquino filed an amended complaint for robbery before the Municipal Trial Court of Buhi, Camarines Sur, alleging that Romeo Matias, Jim Boquiron, Aniano Lascano, and several John Does, in conspiracy and with intent to gain, unlawfully took ninety-six (96) fish cages. 1.2. Aniano Lascano was impleaded as an accessory because he was purportedly found in possession and control of the said cages. 1.3. Judge Jacinto J. Penaflor conducted the preliminary investigation and issued a search and seizure order the same day, directing law enforcement officers to immediately search Lake Bato and seize the specified fish cages.

2.1. On October 21, 1992, while the search and seizure order was being implemented, Romeo Matias filed an ex-parte petition for a restraining order as part of a complaint for grave coercion against complainant Renato V. Aquino and others.
2.2. Respondent Judge Valenciano granted the urgent petition by issuing a temporary restraining order directing the accused to desist from uprooting and gathering fish cages purportedly belonging to Matias. 2.3. The restraining order, although executed, was rendered moot in effect because the fish cages were already taken into custody by the police at Bato, Camarines Sur.

Subsequent Criminal Cases and Additional Proceedings

• Additional Cases Filed by Romeo Matias

1.1. On November 3, 1992, Matias initiated two separate criminal cases charging complainants with robbery: 1.1.1. Crim. Case No. 7127-L for the robbery of five (5) fish cages on October 20, 1992. 1.1.2. Crim. Case No. 7128-L for the robbery of fifty (50) fish cages on October 21, 1992. 2.1. On November 26, 1992, warrants of arrest were issued in connection with the two additional robbery cases. 2.2. Renato V. Aquino filed a motion to quash the restraining order on October 22, 1992, but his failure to appear for the scheduled hearing on November 3, 1992, contributed to the continuation of the contested actions.

Allegations and Evidence of Judicial Misconduct

• Interference with the Order of a Co-Equal Court

1.1. Complainants asserted that respondent Judge was aware of the valid search and seizure order already issued by Judge Penaflor but still issued the restraining order, thus interfering with the action of another court of concurrent jurisdiction. 1.2. The restraining order was alleged to have been granted based on the questionable representation that the fish cages were being uprooted and transferred, despite contrary evidence. 2.1. Respondent Judge was accused of harboring partiality in favor of Romeo Matias, as evidenced by his remarks implying an improper personal involvement between Matias and the complainant. 2.2. Allegations also included that the judge’s conduct demonstrated malicious intent to hinder, delay, and frustrate the administration of justice. 3.1. The Investigating Judge, Rafael P. Santelices, concluded that the respondent judge’s actions amounted to grave abuse of discretion. 3.2. The Office of the Court Administrator similarly recommended disciplinary action, suggesting a fine for the interference with proceedings of a co-equal court.

Issue:

Jurisdiction and Interference

• Whether a court of one jurisdiction has the power to issue a restraining order that interferes with or contradicts a valid search and seizure order issued by another court of equivalent jurisdiction.

Abuse of Judicial Discretion

• Whether the issuance of the temporary restraining order by respondent Judge Valenciano, in light of the pending search and seizure order, constitutes an abuse of discretion and ignorance of established legal procedures.

Allegation of Bias and Partiality

• Whether respondent Judge’s actions, including his alleged remarks in a local dialect and the subsequent issuance of orders in related criminal cases, demonstrate manifest bias in favor of Romeo Matias.

Procedural Due Process and Evidence

• Whether the failure of the complainants to furnish concrete evidence of the search and seizure order at the time of the issuance of the restraining order negates the judge’s reliance on statements and testimonies that led to probable cause findings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)