G.R. No. 147188 - Commissioner of Internal Revenue vs. Estate of Toda, Jr.

On July 18, 2008, Belinda Martizano filed a suit seeking a temporary restraining order (TRO) to stop the implementation of DOTC Department Order No. 2007-28, which exclusively designated the Land Transportation Office (LTO) as the provider of compulsory third party liability (CTPL) insurance required for motor vehicle registration.
The suit, docketed as Civil Case No. MC08-3660 in the Regional Trial Court (RTC) in Mandaluyong City, claimed that the said order would adversely affect Martizano’s livelihood as an insurance agent.

The procedure for assigning cases in the Mandaluyong City RTC involved raffling among different branches to ensure equal distribution.
On July 21, 2008, Civil Case No. MC08-3660 was raffled on a scheduled session that involved the attendance of parties and representatives of the raffle committee.
During the raffle, a roulette containing numbers corresponding to RTC Branches (208, 212, 213, and 214) was used for certain cases; however, in this instance, Judge Cancino-Erum announced that the case would be assigned to Branch 213 because the other branches had already been assigned a TRO/injunction case.

The Government Service Insurance System (GSIS) charged the respondents—Executive Judge Maria A. Cancino-Erum and RTC Judge Carlos A. Valenzuela—with multiple counts including:

Violating the Rules of Court by not following the exclusive raffle method mandated for case assignment.
Grave misconduct and gross ignorance of the law in the handling and assignment of the case.
In the case of Judge Valenzuela, additional charge for knowingly rendering an unjust order by issuing a TRO without the necessary supporting evidence and due notice.

GSIS contended that the non-raffling or modified procedure in the assignment of Civil Case No. MC08-3660 fostered an anomalous situation where litigants could potentially time their filing to have their case assigned to a “favored” branch.

Judge Cancino-Erum defended the assignment procedure by explaining that a long-standing practice existed in which once a branch had already received a TRO/injunction case during a raffle round, it would be excluded from subsequent raffles until all branches were similarly assigned.
She insisted that even though the roulette was not used for Civil Case No. MC08-3660, the assignment was still by raffle and adhered to the practice of equalizing the distribution of urgent TRO cases within the RTC.
Judge Valenzuela maintained that the round system for raffling was customarily observed and that his actions—such as issuing a TRO without waiting for the opposition from all parties—were justified due to the urgent nature of the matter.

On October 2, 2008, GSIS formally charged both judges, basing its allegations on the purported violation of Section 2, Rule 20 of the Rules of Court, which mandates that case assignments be done exclusively by raffle.
The Office of the Court Administrator (OCA) conducted a study and, on April 1, 2009, issued a report stating that the respondents had violated proper raffle procedures as dictated by Supreme Court Circulars (notably Circular No. 20 and Circular No. 7).
The OCA recommended fining each respondent P5,000.00 and treating the matter as a regular administrative complaint, thereby setting the stage for the resolution dated June 3, 2009, which imposed the fines.
In response, the respondents filed separate motions for reconsideration, arguing that their conduct was in keeping with the established practice for handling urgent TRO/injunction cases.

Whether the respondents (Judge Cancino-Erum and Judge Valenzuela) were properly held administratively liable for allegedly violating the established rules on the raffle of cases.

Whether deviation from the strict use of the roulette in raffling, due to the urgency of TRO cases, constitutes a violation of the exclusive raffle requirement under Section 2, Rule 20 and relevant Supreme Court Circulars.
Whether the practice of excluding a branch that has already received a TRO/injunction case is legally defensible despite allegations that it may create an “anomalous situation” favoring a particular judge.
Whether the administrative charges for gross ignorance of the law, grave misconduct, and knowingly rendering unjust orders against the respondents are substantiated by the facts and supported by existing law.