G.R. No. RTJ-03-1779. April 30, 2003
Chief State Prosecutor Jovencito R. Zuño, et al. vs. Judge Arnulfo G. Cabredo, Regional Trial Court, Branch 15, Tabaco City, Albay

FACTS

The Bureau of Customs, through Deputy Collector Atty. Winston Florin, issued a Warrant of Seizure and Detention against a shipment of 35,000 bags of rice for violation of the Tariff and Customs Code. Subsequently, the alleged consignees filed a Petition for Prohibition with a prayer for a Temporary Restraining Order (TRO) before the Regional Trial Court of Tabaco City, presided by respondent Judge Arnulfo G. Cabredo, seeking to enjoin the customs proceedings. Judge Cabredo granted the prayer and issued an ex-parte 72-hour TRO, which led to the release of the seized goods upon the filing of a bond.
Administrative complaints were filed against Judge Cabredo for grave misconduct, knowingly rendering an unjust interlocutory order, manifest partiality, and gross negligence. The complainants, led by Chief State Prosecutor Zuño, alleged that the judge blatantly violated Administrative Circular No. 7-99 and settled jurisprudence, particularly Mison v. Natividad, which holds that the Collector of Customs has exclusive jurisdiction over seizure and forfeiture cases and that regular courts cannot interfere with such proceedings through injunctive reliefs.

ISSUE

Whether respondent Judge Arnulfo G. Cabredo is administratively liable for issuing a Temporary Restraining Order against the Bureau of Customs in a seizure and forfeiture case, thereby interfering with its exclusive jurisdiction.

RULING

Yes, Judge Cabredo is administratively liable for Grave Misconduct. The Supreme Court, per curiam, emphasized the well-settled doctrine of exclusive customs jurisdiction over seizure and forfeiture proceedings, a basic principle that judges are presumed to know. By issuing the TRO, Judge Cabredo unlawfully interfered with the Bureau of Customs’ exercise of its exclusive authority, a direct contravention of Administrative Circular No. 7-99 which cautions judges against issuing such restraining orders in customs cases. His defense—that he believed the Bureau was divested of jurisdiction due to a statement in the warrant—was untenable; even an allegedly illegal seizure does not strip the Bureau of its jurisdiction. This act demonstrated not merely an error of judgment but a gross, inexcusable, and deliberate disregard of established rules and circulars.
The Court found that his issuance of the TRO, under the circumstances, constituted grave misconduct, which is a serious transgression reflecting a corrupt motive or a flagrant disregard of law. It eroded public confidence in the judiciary. Consequently, the Court imposed the penalty of dismissal from service with forfeiture of all benefits (except accrued leave credits) and with prejudice to re-employment in any government agency.