Case Digest (A.M. No. RTJ-07-2089, RTJ-0921-99)
Facts:
Land Bank of the Philippines v. Judge Ernesto P. Pagayatan, A.M. No. RTJ-07-2089 [formerly OCA I.P.I. No. 07-2659-RTJ]; A.M. No. RTJ-0921-99 [formerly OCA I.P.I. No. 07-2698-RTJ], September 08, 2009, Supreme Court En Banc, Carpio Morales, J., writing for the Court.The dispute arose from an agrarian case in which the Provincial Agrarian Reform Adjudicator (PARAD) of Occidental Mindoro, by Decision of March 31, 2003, ordered Land Bank of the Philippines (LBP) to pay Josefina S. Lubrica P71,634,027.30 as just compensation for 431.1407 hectares. Contesting the PARAD’s valuation method, LBP filed on March 5, 2004 a petition for fixing just compensation before the Regional Trial Court (RTC), San Jose, Occidental Mindoro.
On March 4, 2005, respondent Judge Ernesto P. Pagayatan, presiding judge of RTC Branch 46, ordered LBP to deposit the preliminary compensation of P71,634,027.30. LBP sought relief by filing a petition for certiorari with the Court of Appeals (CA G.R. No. 93206), which dismissed it by resolution dated August 17, 2006. Meanwhile, Josefina filed on September 26, 2006 a petition for indirect contempt against LBP officials Leticia Lourdes A. Camara and Teresita V. Tengco, alleging disobedience of the March 4, 2005 order.
Respondent issued a warrant for the arrest of Leticia and Teresita on February 9, 2007; Leticia was arrested on February 12 and detained. LBP deposited the required P71,634,027.30 in cash and bond at its Manila head office in the name of “The Clerk of Court, RTC Branch 46, San Jose, Occidental Mindoro, in the Matter of Agrarian Case No. 1390” and, through counsel for the LBP officials, filed an Urgent Manifestation of Compliance (Feb. 14, 2007) attaching the Certificate of Deposit and moving for quashal/recall of the warrant.
Respondent refused to accept that deposit as substantial compliance, directed technical changes in the payee/account name so that Josefina could immediately withdraw the funds, and held in abeyance disposition of compliance motions pending resolution by the Court of Appeals of LBP’s Omnibus Motion. After the CA denied LBP’s Omnibus Motion, respondent again found the deposit unsatisfactory (Feb. 21, 2007) and ordered the deposit to be in the name of Josefina “as payee, in a form that is readily withdrawable” before ordering Leticia’s release. LBP and the detained officials sought relief by petition for certiorari and mandamus to the CA (CA-G.R. SP No. 98032), and Leticia’s son filed a petition for habeas corpus before the Supreme Court (G.R. No. 176563).
The Supreme Court (in Camara v. Pagayatan, G.R. No. 176563, Apr. 2, 2007) found Leticia’s continued detention unlawful and ordered her liberation; the CA had earlier granted a writ of preliminary mandatory injunction (Mar. 1, 2007) and respondent released Leticia on March 2, 2007. Thereafter, LBP filed an administrative complaint against respondent on August 24, 2007, charging violations including deprivation of liberty without due process, violations of the Anti‑Graft and Corrupt Practices Act, gross ignorance of the law or procedure, knowingly rendering unjust interlocutory orders, malicious delay, arbitrary detention, and breaches of the Code of Judicial Conduct. Leticia filed a separate administrative complaint on October 30, 2007. Respondent defended his actions as having legal basis for the March 4, 2005 order (citing this Court’s decision in Lubrica v. Land Bank of the Philippines, G.R. No. 170220), justified his action on judicial courtesy and procedural amendments to Rule 65, and argued estoppel and forum‑shopping.
The Office of the Court Administrator (OCA), in a memorandum dated October 4, 2008, found the March 4, 2005 orde...(Subscriber-Only)
Issues:
- Was Judge Ernesto P. Pagayatan’s March 4, 2005 Order directing LBP to deposit P71,634,027.30 legally valid?
- Is respondent administratively liable for Gross Ignorance of the Law or Procedure and Gross Misconduct for (a) taking cognizance of an indirect contempt petition despite non‑payment of docket fees and (b) refusing to release Leticia Camara despite LBP’s deposit and attempts to comply?
- Does respondent’s retirement preclude a finding of administrative liability or t...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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