In its ruling, the High Tribunal said an administrative complaint is not an appropriate remedy where judicial recourse is available.
Dismissing the charge of gross ignorance of the law against Judge Cesar Solis of the Manila Regional Trial Court, Branch 14, the Supreme Court’s second division said the complainant, lawyer Rosalio dela Rosa, failed to show the existence of fraud, bad faith or any other motive of Solis when he reversed an appealed decision and dismissed the case before resolving a motion for the issuance of a writ of execution.
"To hold a judge administratively accountable for every erroneous ruling or decision he renders, assuming he has erred, would be nothing short of harassment and would make his position doubly unbearable," read the decision.
"To hold otherwise would be to render judicial office untenable, for no one called upon to try the facts or interpret the law in the process of administering justice can be infallible in his judgment. It is only where the error is tainted with bad faith, malice or dishonesty that administrative sanctions may be imposed against the erring judge."
Dela Rosa claimed that it was the ministerial duty of Judge Solis to issue the writ of execution since the defendant failed to file a supersedes bond, a requisite to stay an execution.
Judge Solis defended his action, saying that the case falls under one of the exceptions to the immediate execution of the judgment pending appeal. He dismissed the appealed case on the basis of reversible errors in the Metropolitan Trial Court’s (MTC) decision, Solis added.
In the second case, the Supreme Court dismissed the complaint of gross misconduct and gross ignorance of the law against Judge Antonio Manzano of the Calamba City, Laguna RTC, Branch 37 after finding that Manzano’s order directing the private prosecutor to comment on the public prosecutor’s motion to downgrade a case from frustrated murder case to frustrated homicide was "purely judicial in nature," and not a proper subject of an administrative complaint.
"The established doctrine and policy is that disciplinary proceedings and criminal actions against judges do not complement, supplement or substitute judicial remedies, whether ordinary or extraordinary," read the decision.
The Supreme Court rejected complainant Nestor Mendoza’s claims that Manzano failed to act on the public prosecutor’s resolution to downgrade the frustrated murder charge against his son.
When a case has already been filed any disposition of the case rests with the sound discretion of the court, the Tribunal added.
In the administrative case against Judge Manuel Contreras of the Ocampo, Camarines Sur Metropolitan Trial Court, the Supreme Court ruled that the matters raised by complainant Jufre P. Osabal, a program host at a Naga City radio station, had already been elevated to the Regional Trial Court for review and correction.
The complainant presented no proof or arguments to prove respondent judge’s alleged illegal treasure hunting and excavation activities, the High Tribunal added.
Osabal filed the administrative case against Contreras who ordered the arrest of Osabal for contempt after he had implicated Contreras in illegal activities on his radio program.
In the fourth case, the Supreme Court dismissed for lack of merit an administrative case for abuse of authority and manifest bias and partiality against Judge Hector Barillo, acting judge of the Guihulngan, Negros Oriental Municipal Trial Court.
In dismissing the case, the high court said the allegations of bias and partiality against Barillo lacked factual support. It does not give credence to charges based on mere suspicion or speculation, the tribunal added.
In a letter-petition, a group of small tenant-farmers alleged, among other charges, that Barillo conspired with Clerk of Court Lucila Tangeres, to fabricate criminal charges against them.
Dismissing the administrative complaint against Judge Renato Gleyo of the Norala-Tiboli-Sto. Niño, South Cotabato Trial Court, the Supreme Court said there was no grave abuse of discretion nor malice on the part of Gleyo when he issued the warrant of arrest against complainant Brett Taylor.
Taylor was a member of the board of directors of the Tribal Mining Corp. in Tiboli, South Cotabato when he and several others were charged with the alleged extraction of mineral ore from the tunnel of a certain Esther Daquil. Gleyo countered that a preliminary investigation was conducted before the warrant of arrest had been issued. — Jose Rodel Clapano