FACTS:

The case involves an administrative complaint against Judge Juanita C. Tienzo of the Regional Trial Court (RTC), Branch 27, Cabanatuan City. The complaint alleges gross ignorance of the law or procedure in connection with two separate cases: one for Replevin or Sum of Money, and the other an appealed case of Unlawful Detainer from the Municipal Trial Court in Cities (MTCC), Branch 3, Cabanatuan City.

In the first charge, the complainant criticizes the respondent judge for issuing a writ of replevin without proper proof of ownership of the subject vehicle. The complainant argues that the plaintiff admitted selling the vehicle to the defendant, and the subject vehicle had been transferred to third persons.

The complainant also asserts that the respondent judge caused a delay in releasing the property despite a third-party claim. The respondent judge granted the plaintiffs an extension of time to post an indemnity bond, which resulted in the subject vehicle remaining with the sheriff beyond the prescribed period.

On the second charge, the complainant alleges that the respondent judge rendered a decision without clearly stating the facts and the law on which it is based. The complainant also criticizes the respondent judge for writing the order in English and in a manner that does not befit an RTC Judge.

The respondent judge opposed the complaint, arguing that the complainant lacked legal standing, that the complaint was baseless and malicious, and that the complainant was not directly affected by the decision in question. The respondent judge contended that any error in the order should be addressed through a petition for certiorari or an appeal. She also disputed the complainant's locus standi to file the complaint regarding the decision.

The complainant asserted that the rule on real party-in-interest does not apply to administrative cases and that he had personal knowledge of the facts alleged, allowing him to file administrative charges against the judge.

The Office of the Court Administrator (OCA) found the complaint partly meritorious. The OCA concluded that the errors alleged against the respondent judge were of a judicial nature, suggesting that the proper remedy lies with the courts for corrective judicial action rather than an administrative complaint.

ISSUES:

1. Whether or not respondent judge should have desisted from issuing the writ of replevin in Civil Case No. 4971.

2. Whether or not respondent judge violated the constitutional mandate to state clearly and distinctly the facts and the law on which her decision in Civil Case No. 4884 is based.

RULING:

1. The Court held that respondent judge should not have issued the writ of replevin in Civil Case No. 4971. Complainant argued that the plaintiff failed to prove ownership of the subject vehicle and that the vehicle had been the object of several conveyances to third persons. The Court found merit in complainant's arguments and agreed that the writ should not have been issued.

2. The Court found that respondent judge violated the constitutional mandate and the rules of court by failing to state clearly and distinctly the facts and the law on which her decision in Civil Case No. 4884 is based.

PRINCIPLES:

• The error imputed to the respondent judge in her challenged order is of a judicial character. Complainant's remedy lies with the courts for the appropriate corrective judicial action, and not in this administrative complaint.

• The constitutional mandate and the rules of court require judges to state clearly and distinctly the facts and the law on which their decisions are based.

• The rule on real party-in-interest does not apply to administrative cases. A party who has personal knowledge of the facts alleged in the complaint may lodge administrative charges against an erring judge.