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CECILIA GADRINAB SENARLO v. JUDGE MAXIMO G.W. PADERANGA

FACTS:

Complainant Senarlo filed an administrative complaint against Judge Paderanga, Presiding Judge of RTC Branch 38, Cagayan de Oro City, for gross ignorance of the law, knowingly rendering unjust judgment, and grave abuse of authority. The complaint stemmed from Civil Case No. 2005-160, an action for reconveyance and quieting of title filed by Bacalzo against the Archbishop of the Roman Catholic Church of Cagayan de Oro City. Bacalzo sought to recover a piece of land donated to the church, alleging that it was no longer being used for its intended purpose. Bacalzo, who was in the United States, was represented by Senarlo.

Judge Paderanga referred the case for mediation to the Philippine Mediation Center (PMC) and instructed the parties to appear for mediation proceedings on November 4, 2005. However, on October 14, 2005, a proclamation declared November 4, 2005, a non-working holiday. Bacalzo and her counsel went to the PMC on November 7, 2005, and requested to reset the mediation conference. The request, which was not signed by the Archbishop and his counsel, was approved by the mediator. Another request for resetting was subsequently executed but was also not signed by the Archbishop and his counsel. Despite this, Judge Paderanga issued an order on November 9, 2005, dismissing the case for the failure of the parties to appear at the mediation conference. Senarlo filed the administrative complaint against Judge Paderanga, alleging gross ignorance of the law and grave abuse of authority.

Judge Paderanga denied the allegations, stating that he did not dismiss the case without any basis or out of bias and hostility. He claimed that when he issued the order for the mediation conference, November 4, 2005, had not yet been declared a holiday. He also argued that Senarlo could have filed a motion for reconsideration instead of the administrative case. The Office of the Court Administrator recommended finding Judge Paderanga guilty of grave abuse of authority and imposing a fine of P10,000.

ISSUES:

  1. Whether Judge Paderanga committed gross ignorance of the law by issuing the November 9, 2005 Order dismissing Civil Case No. 2005-160 without considering that November 4, 2005, the scheduled date for mediation, was declared a holiday.

  2. Whether Judge Paderanga gravely abused his authority by issuing the November 9, 2005 Order in the absence of the corresponding Mediator's Report.

RULING:

  1. Judge Paderanga did not commit gross ignorance of the law in issuing the November 9, 2005 Order. The Court held that Judge Paderanga could not have known that November 4, 2005, the scheduled date for mediation, would be declared a holiday. Moreover, the Court noted that Bacalzo and her counsel requested for the resetting of the mediation conference, which indicated that they were aware of the scheduled date prior to the holiday.

  2. Judge Paderanga did not gravely abuse his authority in issuing the November 9, 2005 Order in the absence of the corresponding Mediator's Report. The Court considered the Manifestation (Mediator's Report) dated November 7, 2005, received by the RTC on November 8, 2005, as sufficient evidence of non-appearance during the mediation conference. The Court also emphasized that the purpose of mediation is for the parties to reach a possible settlement, and the failure of Bacalzo to appear during the proceedings indicated lack of interest to pursue the case.

PRINCIPLES:

  • Ignorance of the law is not a ground to hold a judge administratively liable unless it is accompanied by bad faith, fraud, dishonesty, or corruption.

  • The parties in a case are expected to keep track of scheduled proceedings and are responsible for their non-appearance.

  • Mediation conferences are held to facilitate possible settlements, and non-appearance by a party can be interpreted as lack of interest to pursue the case.