Gross ignorance

A judge may be held administratively liable for gross ignorance of the law. This case of a Regional Trial Court Judge explains what “gross ignorance of the law” means.

This case is actually one of the three complaints filed by Magno against the same Judge ES in Adm. Case No. RTJ-03-1781. In this case, Magno charged Judge ES with serious irregularities, dishonesty and grave misconduct in the improper execution of the final decision in an Agrarian Case (Nos. 31-99 to 51-99) entitled Soriano Fruits et.al. vs. Department of Agrarian Reform (DAR) and/or Land Bank of the Philippines (LBP). The dispositive portion of said decision already fixed and determined the total amount of just compensation to be paid to the landowner of 123.4629 hectares of land together with the improvements thereon at P111, 533,686.14 taking into consideration the upgraded amount after properly computing the adjustment to make such valuation at par with the current true value of the Peso against the U.S. Dollar plus 6% interest per annum. This judgment was entered in the Book of Entries of the Special Agrarian Court on May 3, 2000.

In July 2000, Judge ES was designated as Acting Presiding Judge of the said Special Agrarian Court. Then on October 26, 2000 Judge ES made further adjustment of the judgment amount. In explaining his action, Judge ES contended that he merely acted on the motion filed by the landowner who requested adjustments in enforcing the final judgment considering the statement in the dispositive portion that allowed adjustments based on the current true value of the Philippine Peso vis-à-vis the US Dollar. Was Judge ES correct?

No. Judge ES ought to know that the decision of the Special Agrarian Court was already final and executory and could no longer be disturbed when he made the adjustments. This legal reality, known as immutability of judgment, is an elementary principle of law and procedure. Once a judgment becomes final, it may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether it is attempted to be made by the court rendering it or by the Highest Court of the land. The only recognized exceptions are the correction of clerical errors, or the making of the so called nunc pro tunc (“now for then”) entries which cause no prejudice to any party, and where the judgment is void. Judge ES’s ground for modifying the decision is not among these recognized exceptions.

For modifying a final and executory decision in the course of its execution, Judge ES is guilty of gross ignorance of the law. Where the law is straightforward and its application to the facts plainly evident, not to know the law or to act as if he does not know it, constitute gross ignorance of the law. Judge ES violated Rule 3.01, Canon 3 of the Code of Judicial Conduct which mandates professional competence on the part of a judge. A judge owes the public and the court the duty to be proficient in the law and is expected to keep abreast of laws and prevailing jurisprudence; otherwise, he erodes the confidence of the public in the courts. Ignorance of the law by a judge can easily be the mainspring of injustice. So Judge ES is meted the maximum fine of P40,000 to be deducted from his retirement benefits (Mercado vs. Salcedo, A.M. No. RTJ-03-1781, October 16, 2009, 604 SCRA 4).

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