Urbina v. Maceren
REITERATIONFacts
The Antecedents: Complainants Gaudencio S. Urbina and Vedasto B. Gesmundo filed an administrative complaint against respondent Judge Maximo A. Maceren. Subsequently, complainant Urbina filed a motion for suspension and/or to declare respondent and Atty. Marcial Esguerra in contempt of court, alleging grave threats against his life if he did not withdraw his complaints. The Office of the President also referred complainant Gesmundo's letter objecting to the re-appointment of respondent judge for comment. Procedural History: The Supreme Court had previously dismissed the initial complaint for failure to make out a prima facie case. The respondent judge submitted his comment, which included the dismissal by the acting provincial fiscal of Laguna of complainant Urbina's criminal complaint for "Knowingly Rendering an Unjust Judgment." The fiscal ruled that the decision was sub judice as it was pending appeal, and there was no basis to conclude the respondent judge knew his judgment was unjust. The respondent judge also denied making threats, stating he merely asked Atty. Esguerra to inform Urbina to limit his action to an ordinary appeal. Atty. Esguerra submitted an affidavit corroborating the denial of threats. The Petition: The Court considered Urbina's "joint motion" for suspension and/or contempt in light of the respondent's comment and the dismissal of the criminal complaint.
Issue(s)
Whether the respondent judge committed grave threats against complainant Urbina. Whether the respondent judge knowingly rendered an unjust judgment. Whether the complainants' actions constitute unwarranted harassment.
Ruling
The Court denied complainant Urbina's "joint motion" for suspension and/or contempt. The Court directed the Clerk of Court to furnish the Office of the President with copies of the resolution and the previous resolution dismissing the complaint.
Ratio Decidendi
On the issue of grave threats and knowingly rendering an unjust judgment: The Court found the charge of threats unsustainable, resting on complainant's bare assertion against the respondent's categorical denial supported by Atty. Esguerra's affidavit. The Court noted the previous dismissal of the administrative complaint for failure to establish a prima facie case and the correct dismissal by the fiscal of the criminal complaint for "Knowingly Rendering an Unjust Judgment." The fiscal correctly ruled that the issue of whether the judgment was unjust was sub judice, as it was pending appeal. Furthermore, the fiscal found no basis to conclude that the respondent judge knew his judgment was unjust, as his view on the limitations of a probate court's power to decide title to real properties was supported by Supreme Court decisions. The Court found it difficult to give credence to the complaint for threats, as it would have been foolhardy and pointless for the respondent to have asked Atty. Esguerra to make such threats, especially with another complainant (Gesmundo) remaining. On the issue of unwarranted harassment: The Court expressed satisfaction that the complainants' charges could not be sustained. The Court reiterated that judges will not be held administratively liable for mere errors of judgment absent malice or gross ignorance. The Court cited Dizon vs. de Borja (37 SCRA 46, 52) for the principle that holding a judge accountable for every erroneous ruling would be harassment. In this case, the verdict complained of was far from erroneous, being under review on appeal. The Court found the respondent's comment satisfactory and decided not to subject him to further needless harassment and distraction by giving due course to the complaint-motion. On the conduct of complainants and members of the bar: The Court enjoined complainants and members of the bar to file administrative complaints against judges with circumspection, without disrespectful language or offensive personalities, to avoid unduly burdening the Court. It reminded lawyers of their fidelity to the courts and that filing unfounded or frivolous charges against judges, or using offensive language to harass them, can subject lawyers to disciplinary action as officers of the Court.
Main Doctrine
Administrative complaints against judges for alleged unjust judgments, especially when the decision is pending appeal and lacks a prima facie basis, will not be sustained absent clear evidence of malice or gross ignorance, and may subject complainants to disciplinary action for harassment.