EDGAR R. ERICE v. PRESIDING JUDGE DIONISIO C. SISON

FACTS:

The complainant, Edgar R. Erice, filed an administrative matter against retired Judge Dionisio C. Sison of the Regional Trial Court (RTC) in Caloocan City. The complaint alleges that Judge Sison violated certain provisions of A.M. No. 01-8-10-SC, specifically, gross misconduct, knowingly rendering an unjust judgment or order, and gross ignorance of the law or procedure.

The complaint arose from a case filed by Erice, who was then the Vice Mayor of Caloocan City, against the then Mayor Enrico R. Echiverri and other city officials for alleged violation of the Government Service Insurance System Act. The Ombudsman issued an Order of Preventive Suspension against Echiverri and others, which was later affirmed by the Court of Appeals (CA).

Echiverri and others then filed a Petition for Declaratory Relief with the RTC of Caloocan City, seeking a judicial declaration on their rights and obligations with respect to the implementation of their suspension. The case was initially assigned to Judge Lorenza R. Bordios, but she inhibited herself and the case was re-raffled to Judge Sison.

During the proceedings before Judge Sison, Erice and the Department of Interior and Local Government (DILG) questioned the jurisdiction of the RTC to hear the case, as well as raised the issue of forum shopping. Despite these objections, Judge Sison proceeded with the hearing and allowed Echiverri and others to present evidence. He also extended the temporary restraining order (TRO) to 20 days and granted a writ of preliminary injunction.

Judge Sison denied the allegations against him and claimed that he did not violate the right to due process. He argued that the extension of the TRO was to allow Echiverri and others to file their written comment and argue against the motion to dissolve. He also argued that there was no "deplorable haste" in issuing the TRO and writ of preliminary injunction.

The Office of the Court Administrator (OCA) recommended that Judge Sison be found guilty of gross ignorance of the law and fined one month's salary, with a warning of more severe penalties for any repeat offense.

ISSUES:

  1. Whether or not Judge Sison violated Section 8, paragraphs 3, 4, and 9 of A.M. No. 01-8-10-SC.

  2. Whether or not Judge Sison committed gross misconduct, knowingly rendered an unjust judgment or order, and gross ignorance of the law or procedure.

RULING:

  1. The Court held that Judge Sison is guilty of gross ignorance of the law. He violated Section 8, paragraphs 3, 4, and 9 of A.M. No. 01-8-10-SC. He committed gross misconduct, knowingly rendered an unjust judgment or order, and displayed gross ignorance of the law or procedure. Judge Sison is fined an amount equivalent to his one-month salary with a warning that a repetition of the same or similar act shall be dealt with more severely.

PRINCIPLES:

  • Violations of Section 8, paragraphs 3, 4, and 9 of A.M. No. 01-8-10-SC constitute gross misconduct, knowingly rendering an unjust judgment or order, and gross ignorance of the law or procedure.