ROCKLAND CONSTRUCTION CO., INC., REPRESENTED BY EMMANUEL ZAPANTA, COMPLAINANT, VS. JUDGE MARIANO M. SINGZON, JR., REGIONAL TRIAL COURT, BRANCH 67, PASIG CITY, RESPONDENT.

Rockland Construction versus Judge Singzon

The Case

This is an administrative case filed by Rockland Construction Company, represented by its president Emmanuel Zapanta, against Judge Mariano Singzon, Junior, presiding judge of a branch of the Regional Trial Court of Pasig City. Rockland charges the judge with gross ignorance of the law and procedure, knowingly rendering an unjust judgment, and violation of the Code of Judicial Conduct, arising from two orders he issued in a case for indirect contempt. The case matters because it fixes the outer limits of a judge's jurisdiction: a judge may not decide questions that were never submitted to him, and he may not admit an intervenor after he has already rendered judgment. It is a staple in the law on judicial ethics and disciplinary liability.

Procedural History

The controversy began in the trial courts of Pasig City. Rockland sued Mid-Pasig Land Development Corporation for specific performance with damages, docketed as Civil Case Number 68213, and that case was raffled to a branch presided over by Judge Rodrigo Lorenzo. Mid-Pasig, in turn, filed an unlawful detainer case against Rockland, docketed as Civil Case Number 8788, before the Metropolitan Trial Court of Pasig City, Branch 70. The Metropolitan Trial Court dismissed the ejectment case on the ground that the issue was not one of possession but the exercise of an option to renew a contract, which was beyond pecuniary estimation. Meanwhile, the Supreme Court, in a decision promulgated in October 2003, granted Mid-Pasig's petition, reversed the Court of Appeals, and ordered the dismissal of Civil Case Number 68213, upholding the jurisdiction of the Metropolitan Trial Court over the ejectment case. Rockland's motion for reconsideration of that decision was denied with finality in February 2005.

While that motion for reconsideration was still pending, Rockland filed before the Regional Trial Court of Pasig City a petition charging Mid-Pasig and Ernesto Jalandoni with indirect contempt, docketed as SCA Number 2673 and raffled to the branch presided over by Judge Singzon. Judge Singzon dismissed the petition in a resolution dated September 17, 2004, and in an omnibus order dated November 12, 2004 he denied Rockland's motion for reconsideration, granted the motion to intervene filed by Pasig Printing Corporation, and granted immediate execution. A writ of execution issued on November 16, 2004. Rockland then filed a petition for certiorari before the Court of Appeals, which partially affirmed the resolution and omnibus order only insofar as they dismissed the contempt charge, and annulled and set aside the same orders in all other respects, including the grant of the motion to intervene and the writ of execution. Pasig Printing Corporation elevated the matter to the Supreme Court, which denied its petition and later denied its motion for reconsideration with finality. In the meantime, Rockland filed this administrative complaint against Judge Singzon in December 2004. The Office of the Court Administrator recommended that the judge be found liable for gross ignorance of the law and procedure and fined 20,000 pesos. The case reached the Supreme Court as an original administrative matter against a judge.

Facts

Rockland leased from Mid-Pasig a parcel of land known as the site of Payanig sa Pasig, and subleased it to MC Home Depot. When a dispute arose over the renewal of the lease, Rockland sued Mid-Pasig for specific performance, asking that Mid-Pasig be compelled to execute a written contract of lease in its favor, and obtained an injunctive order restraining Mid-Pasig from ejecting it from the premises. Mid-Pasig countered with an unlawful detainer case, which the Metropolitan Trial Court eventually dismissed for lack of jurisdiction over a matter beyond pecuniary estimation.

While Rockland's motion for reconsideration of the Supreme Court's decision dismissing its specific performance case was still pending, Rockland filed a petition for indirect contempt against Mid-Pasig and Jalandoni before Judge Singzon's branch. In his resolution of September 17, 2004, Judge Singzon dismissed the contempt petition, but he went further: he declared that the lease between Rockland and Mid-Pasig had evidently expired without being renewed, took note that Rockland had lost its possessory right over the property, and directed Rockland to refrain from exercising any possessory right over it.

Rockland moved for reconsideration. Almost a month after the resolution, Pasig Printing Corporation, a stranger to the contempt case, filed a motion to intervene, asking for immediate execution and for authority to padlock the premises. In his omnibus order of November 12, 2004, Judge Singzon denied Rockland's motion for reconsideration, granted the intervention, granted immediate execution, and directed the sheriff to implement the resolution, employing reasonable force if necessary, including the padlocking of the MC Home Depot premises. A writ of execution issued, and possession was turned over to Pasig Printing Corporation. Judge Singzon later voluntarily inhibited himself from further hearing the case.

Issues

• Whether or not Judge Singzon acted without jurisdiction when he ruled on the possessory rights of the parties in a case that was solely an action for indirect contempt.
• Whether or not Judge Singzon erred in granting Pasig Printing Corporation's motion to intervene after he had already rendered judgment in the contempt case.
• Whether or not Judge Singzon is administratively liable for gross ignorance of the law and procedure, and if so, what penalty should be imposed.

Applicable Provisions

Section 2 of Rule 19 of the Rules of Court, on intervention, provides:

A person who has a legal interest in the matter in litigation, or in the success of either of the parties, or an interest against both, or is so situated as to be adversely affected by a distribution or other disposition of property in the custody of the court or of an officer thereof may, with leave of court, be allowed to intervene in the action. The court shall consider whether or not the intervention will unduly delay or prejudice the adjudication of the rights of the original parties, and whether or not the intervenor's rights may be fully protected in a separate proceeding.

This provision governs the timeliness and the requisites of intervention, and the Court held that a motion to intervene may be filed only at any time before rendition of judgment by the trial court.

Section 8 of Rule 140 of the Rules of Court, on serious charges, provides:

Serious charges shall be punished with dismissal from the service, suspension from office without salary and other benefits for more than three but not exceeding six months, or a fine of more than Twenty Thousand Pesos but not exceeding Forty Thousand Pesos.

This provision supplies the penalty for gross ignorance of the law and procedure, which the Court classified as a serious charge.

Ruling

On the first issue, the Court held that Judge Singzon exceeded his jurisdiction. The only issue submitted for resolution in the contempt case was whether Mid-Pasig had committed indirect contempt of court. The Court stressed that a judge should know the limits of his jurisdiction, and that jurisdiction is vested by law and not dependent on the prayer of the parties. By ruling on matters pertaining to preliminary possessory rights, the judge acted beyond the scope of the case before him. The Court reminded that an indirect contempt proceeding is a separate proceeding which deals with a defiance of the authority, justice, or dignity of the court.

On the second issue, the Court held that the judge erred in allowing Pasig Printing Corporation to intervene. There was no compelling reason to grant the motion, because the intervenor had no legal interest in the matter in litigation and was not an indispensable party. The option to lease attached by Pasig Printing Corporation to its motion even excluded the MC Home Depot area, which was the property in litigation. More fundamentally, the motion to intervene was filed after the judge had already decided the contempt case, and the Court held that after trial and decision in a case, intervention can no longer be permitted.

On the third issue, the Court held that for resolving the possessory rights of the parties in an action for indirect contempt, and for allowing the intervention after a decision had already been rendered, the judge exceeded his jurisdiction and disregarded the rules of procedure. He is therefore guilty of gross ignorance of the law and procedure. The Court quoted the maxim that ignorance of the law, which everyone is bound to know, excuses no one, not even judges. Gross ignorance of the law or procedure is a serious charge under Section 8 of Rule 140, punishable by dismissal, suspension, or a fine of more than 20,000 pesos but not exceeding 40,000 pesos. Under the circumstances, the Court found a fine of 40,000 pesos to be in order.

Doctrine

A judge's jurisdiction is vested by law and is not dependent on the prayer of the parties; he must know the limits of his jurisdiction and may not resolve matters that were never submitted to him. An indirect contempt proceeding is a separate proceeding that deals with a defiance of the authority, justice, or dignity of the court, and the judge therein may not adjudicate the possessory rights of the parties.

Under Section 2 of Rule 19, intervention may be allowed only before rendition of judgment by the trial court; after trial and decision, intervention can no longer be permitted. The intervenor must also have a legal interest in the matter in litigation, and the court must consider whether the intervention will unduly delay or prejudice the adjudication of the rights of the original parties.

Gross ignorance of the law and procedure is a serious charge under Section 8 of Rule 140, punishable by dismissal from the service, suspension from office without salary and other benefits for more than three but not exceeding six months, or a fine of more than 20,000 pesos but not exceeding 40,000 pesos. Ignorance of the law, which everyone is bound to know, excuses no one, not even judges.

Disposition

The Court found Judge Mariano Singzon, Junior guilty of gross ignorance of the law and procedure and ordered him to pay a fine of 40,000 pesos, with a warning that a repetition of the same or similar acts will be dealt with more severely.

Remember This

Memorize this line: jurisdiction is vested by law and not dependent on the prayer of the parties, and after judgment, intervention can no longer be permitted. Examiners use this case in judicial ethics and disciplinary law to test gross ignorance of the law and procedure under Section 8 of Rule 140, and in remedial law to test the timeliness and requisites of intervention under Section 2 of Rule 19.