**Facts:**
1. **Initial Filings (1980):** Spouses Villa Macasasa and Gertrudes Lanutan were involved in two civil cases, Civil Case No. 1942 for reconveyance with damages and preliminary injunction, and Civil Case No. 1950 for recovery of possession with writ of preliminary injunction, which were filed before the Regional Trial Court, Branch 18, Pagadian City under Judge Fausto H. Imbing.
2. **RTC Decision (1994):** On February 10, 1994, the RTC ruled to dismiss Civil Case No. 1942 and ordered Villa Macasasa, in Civil Case No. 1950, to vacate the disputed land and pay Juanita Sicad P5,000 for attorney’s fees and all incidental expenses.
3. **Post-Judgment Proceedings (1996):** On August 6, 1996, Judge Imbing issued an order denying a motion to quash execution, levying a property of Villa Macasasa, and setting attorney’s fees and additional costs amounting to P1,200,000.
4. **Contempt and Arrest Order (1996):** On September 5, 1996, Judge Imbing issued a warrant of arrest against Villa Macasasa, Gertrudes Lanutan, and two others for alleged indirect contempt, fixing bail at P5,000 each without hearing.
5. **Appeals Dismissed:** Their appeal to the Court of Appeals was dismissed on November 29, 1995, due to non-compliance with procedural requirements, becoming final on March 29, 1996.
6. **Administrative Complaint:** On February 25, 1997, Villa Macasasa and Gertrudes Lanutan filed a complaint against Judge Imbing for grave abuse of authority, serious misconduct, and gross ignorance of the law.
7. **Respondent’s Answer (1997):** Judge Imbing denied wrongdoing, asserting that the appeal was already dismissed, and his orders were lawful, justified by the necessity to enforce the court’s decision.
8. **Retirement and Resolution Process (1997-1999):** Judge Imbing retired in 1997, filed a motion requesting retirement benefits, and offered P40,000 to be withheld pending case resolution. The case was referred to Justice Romulo S. Quimbo for investigation.
**Issues:**
1. Whether Judge Imbing exhibited grave abuse of authority, gross ignorance of the law, and serious misconduct in issuing the orders.
2. Whether adding P1,200,000 as incidental expenses without hearing and amending a final judgment was justified.
3. Appropriateness of issuing a warrant of arrest for indirect contempt without a hearing.
**Court’s Decision:**
1. **Grave Abuse and Procedural Errors:** The Court found that respondent Judge Imbing lacked authority and violated due process principles. The order adding P1,200,000 as costs without it being part of the original judgment was excessive and unjustified.
2. **Ignorance of Procedural Law:** Imbing showed gross ignorance by failing to recognize the limits of judicial power and not adhering to due process, specifically procedural requirements for assessing costs.
3. **Improper Issuance of Arrest Warrants:** The order to arrest for indirect contempt without proper hearing further confirmed procedural ignorance and misconduct.
4. **Conclusion and Penalty:** The Court imposed a fine on Judge Imbing, deducting it from his retirement benefits withheld, due to ignorance rather than malice.
**Doctrine:**
1. **Judicial Authority and Due Process:** Judges cannot amend final judgments to include unadjudicated claims, and must respect due process rights by ensuring all parties have an opportunity to be heard.
2. **Costs and Bill of Costs Requirements:** Strict adherence to procedural rules for taxing costs and incidental expenses must be maintained.
**Class Notes:**
– Key concepts include RULES OF COURT PROCEDURE: pertains to the specific steps courts must follow in granting motions or writs, such as due process for assessing costs.
– Elements of INDIRECT CONTEMPT: Must involve defiance of court orders, typically requiring formal charges and hearings.
**Historical Background:**
This case exemplifies judicial error during post-judgment proceedings, stressing the importance of procedural knowledge and due process adherence in the Philippine judiciary. The decision underscores the continued oversight and accountability of judicial officers, even post-retirement, reinforcing public trust in judicial processes. The judgment serves as a critical reflection of the procedural standards expected within the judiciary during the late 20th century in the Philippines.
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