Ma. Regina Peralta v. Judge Omelio (RTC Davao City) / Romualdo Mendoza v. Judge Omelio / Atty. Cruzabra v.

Judge Omelio (2013) Per Curiam.

FACTS:
These are three consolidated administrative complaints brought against Judge Omelio of RTC Davao City.

ONLY the third case, Cruzabra v. Omelio is relevant:

(1) Cruzabra is the Acting Registrar of Deeds of Davao City.
(2) A special proceeding for reconstitution of title was filed by Helen Denila with the RTC wherein Judge
Omelio was the presiding Judge.
(3) The special proceeding was filed despite the fact that the SC had already ruled against the reconstitution
in a prior case “Heirs of Don Constancio Guzman Inc. v. Hon. Judge Emmanuel Carpio”.
(4) Despite this ruling, Judge Omelio granted the petition of Helen Denila.
(5) OSG and Cruzabra attempted various legal procedures to reverse the decision. Cruzabra also refused to
reconstitute the titles as ordered and was eventually charged for indirect contempt by Judge Omelio.
(6) An administrative investigation was conducted with the following findings:
a. The first two cases to be dismissed for lack of merit.
b. Cruzabra v. Omelio – Investigating judge found that Omelio was guilty of gross ignorance of the
law; recommendation that he be dismissed from service and forfeiture of his benefits.

ISSUE: WON Judge Omelio was guiltly of gross ignorance of the law. (YES)

SC: Guilty of gross ignorance of the law. Should have taken judicial notice of prior decision.
(1) Rule 129, Section 1 – prior SC decisions fall under “official acts of … judicial departments of the
Phillippines”
(2) Decisions of courts form part of the legal system and failure of any court to apply them shall constitute an
abdication of its duty to resolve a dispute in accordance with law, and shall be a ground for administrative
action against an inferior court magistrate (citing Petran Development Inc v. CA).
(3) The Supreme Court had already ruled against reconstitution of titles in Heirs of Don Constancio Guzman
Inc. v. Hon. Judge Emmanuel Carpio.
(4) Judge Omelio was guilty of gross ignorance of the law for failing to take judicial notice of this prior
decision of a superior court (as well as reversing a prior inhibition and taking cognizance of the motion for
indirect contempt).
(5) “Where the law is straightforward and the facts so evident, not to know it or to act as if one does not
know it constitutes gross ignorance of the law”.