I.P.I. No. 16-241-CA-J - Atoc vs. Camello

Complainant Clemente F. Atoc filed a verified complaint on January 12, 2016, against Associate Justices Edgardo A. Camello, Oscar V. Badelles, and Perpetua T. Atal-PaAo of the Court of Appeals, Cagayan de Oro City.
The complaint charged the justices with multiple violations including gross ignorance of the law, gross violation of the attorney’s oath, and assorted breaches of the Code of Professional Responsibility, Judicial Conduct, Professional Ethics, and Judicial Ethics.
Additional allegations included grave abuse of authority, gross misconduct, manifest partiality, and violations of specific provisions of Republic Act No. 6713 and Republic Act No. 3019.

The complaint stemmed from resolutions issued in CA-G.R. SP Nos. 07072-MIN and 07073-MIN involving a case entitled “Oscar S. Moreno and Glenn C. BaAez v. Han. Conchita Carpio Morales…” wherein the resolutions pertained to the enforcement of an Ombudsman decision.
On March 13, 2015, William G. Guillani filed a complaint before the Office of the Ombudsman-Mindanao (OMB) against Oscar S. Moreno and Glenn C. BaAez for grave abuse of authority, grave misconduct, and violation of R.A. No. 6713.
The OMB (in its August 14, 2015 decision) found Moreno and BaAez administratively guilty of grave misconduct, imposing dismissal and additional penalties, while dismissing other charges.

Issuance of Temporary Restraining Order (TRO) and Writ of Preliminary Injunction

On November 13, 2015, the Court of Appeals issued a TRO enjoining the DILG and its agents from enforcing the OMB decision dismissing Moreno and BaAez.
On November 18, 2015, the Court clarified the TRO’s validity, emphasizing that the status quo before the DILG was represented by Moreno and BaAez as the incumbent officers.
On January 11, 2016, the CA elevated the TRO to a Writ of Preliminary Injunction which remained effective throughout the pendency of the related action, thereby barring the enforcement of the OMB decision.

Following the issuance of the TRO and the subsequent Writ of Preliminary Injunction, complainant Atoc alleged that the justices in question had engaged in acts amounting to judicial impropriety and misconduct.
The respondent associate justices, in their Joint Comment submitted on October 11, 2016, argued that the administrative complaint was improper since judicial remedies for contentious rulings were still available.
The respondents emphasized that judicial acts taken in good faith—regardless of perceived error—should not be subjected to administrative discipline, and that the issue was properly for judicial review through appropriate motions such as reconsideration or certiorari.

The Department of the Interior and Local Government (DILG) served and implemented the OMB decision before the receipt of the CA TRO, which later led to questions about the proper recognition of office-holders in Cagayan de Oro City.
Subsequent administrative and judicial filings highlighted the timing discrepancies—such as the DILG’s manifestation on November 17, 2015—underscoring issues with the implementation of the TRO.
The administrative complaint also noted procedural concerns regarding the simultaneous availability of judicial remedies and the filing of administrative actions against judges who were not parties or privies to the pending suit.

Whether the issuance of the TRO and the subsequent Writ of Preliminary Injunction by the CA justices amounted to acts subject to administrative disciplinary action.
Whether the administrative complaint was the proper mechanism to challenge judicial acts when judicial remedies such as motions for reconsideration or certiorari remained available.

Whether the alleged violations—ranging from gross ignorance of the law, breach of professional oaths, to manifest partiality—were sufficient to warrant administrative disbarment or removal from the IBP.
Whether demonstrable evidence existed to show that the respondent justices acted with bad faith, malicious intent, or a deliberate disregard for judicial propriety.

Whether the preclusive principle bars the filing of an administrative complaint against judicial officers when there is an ongoing judicial remedy addressing the same issues.
Whether the complaint improperly bypassed the exclusivity of judicial review in resolving errors made by judges during the performance of their official duties.