A.M. No. 20-08-05-SC. February 16, 2021 (Case Brief / Digest)

**Title:** Judicial Misstep: The Case of JBros Construction Corporation v. Department of Health and GPPB

**Facts:**
This case involves the Department of Health (DOH) and JBros Construction Corporation (JBROS), which entered into contracts for the construction of Barangay Health Stations. The DOH suspended Phase II due to alleged delays in project commencement, attributed by JBROS to the failure of the DOH in delivering the project sites timely. In response, JBROS issued a Notice of Termination, which was followed by a Notice of Termination from the DOH, attaching a report detailing alleged project irregularities by JBROS. This led to JBROS being blacklisted, disqualifying it from participating in government procurement projects.

JBROS contested the blacklisting order by filing separate petitions in two Regional Trial Courts (RTCs) – one presided by Judge Enciso (which was dismissed) and another refiled as a separate petition under a different nomenclature before Judge Soriaso’s sala. The latter court granted a preliminary injunction favoring JBROS, an action which raised questions about judicial propriety, given the prior denial of similar relief by Judge Enciso and allegations of forum shopping by JBROS.

**Issues:**
1. Whether the issuance of a preliminary injunction by Judge Soriaso, despite an earlier denial of the same relief by Judge Enciso, violated the doctrine of judicial stability.
2. Whether Judge Soriaso erred in failing to recognize forum shopping by JBROS.
3. Whether the failure to acknowledge that the contract between JBROS and the DOH had been terminated affected the propriety of granting a preliminary injunction.

**Court’s Decision:**
The Supreme Court sided with the findings of the Office of the Court Administrator (OCA), ruling that Judge Soriaso displayed gross ignorance of the law by violating the doctrine of judicial stability and the rule against forum shopping. It was held that both cases, despite being filed under different nomenclatures, sought the same remedy and involved the same parties, thereby constituting forum shopping. The decision emphasized that ignorance of the law, especially when it directly contributes to judicial confusion and potential injustice, warrants administrative sanctions. As a result, Judge Soriaso was found liable and fined.

**Doctrine:**
This case reinforces the following legal doctrines:
1. The Doctrine of Judicial Stability: which prohibits courts of concurrent jurisdiction from interfering with each other’s orders and judgments.
2. The prohibition against Forum Shopping: which is the act of a party filing multiple cases based on the same cause of action, seeking a favorable opinion by changing the venue or jurisdiction.

**Class Notes:**
1. Doctrine of Judicial Stability: A judge must respect the orders and judgments of courts of concurrent jurisdiction.
2. Rule against Forum Shopping: Filing multiple petitions for the same relief involving the same parties and facts in different courts is prohibited and constitutes an act of deception against the judiciary.
3. Administrative Liability for Judges: Judges may face sanctions for gross ignorance of the law, especially when their errors contribute to judicial confusion and potential injustice.
4. Importance of Fact-Finding: Judges must ensure thorough examination of facts, including awareness of related cases, to prevent contradictory decisions.

**Historical Background:**
This case is situated within the broader context of government procurement and the execution of public projects in the Philippines. The legal mechanisms, such as the blacklisting of contractors for alleged project irregularities, aim to ensure accountability and integrity within public procurement processes. Moreover, this case sheds light on the judiciary’s role in resolving disputes arising from government contracts, emphasizing the importance of judicial propriety, awareness, and adherence to established legal doctrines to maintain the stability and predictability of legal outcomes in the realm of public administration and procurement.


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