Cortez v. Constantino
REITERATIONFacts
The Antecedents: Complainant Rodrigo Cortez filed an administrative complaint for grave abuse of discretion against respondent City Judge Avelino Constantino. The complaint stemmed from the respondent judge's decision acquitting Cerilo Regala in a criminal case for slight physical injuries. The respondent judge found the version of the accused, Regala, to be more credible than that of the complainant, Cortez. Procedural History: The respondent judge rendered a decision acquitting the accused, Cerilo Regala, in Criminal Case F-162779. The aggrieved party, Rodrigo Cortez, subsequently filed an administrative complaint against the judge. The Petition: The administrative complaint alleged grave abuse of discretion on the part of respondent City Judge Avelino Constantino for acquitting Cerilo Regala. The complainant argued that the judge erred in appreciating the evidence and in finding the accused not guilty of slight physical injuries.
Issue(s)
Whether respondent City Judge Avelino Constantino committed grave abuse of discretion in acquitting the accused in Criminal Case F-162779.
Ruling
The administrative complaint against respondent Manila City Judge Avelino Constantino is dismissed. The Court found no legal foundation for the charge of grave abuse of discretion.
Ratio Decidendi
On Whether respondent City Judge Avelino Constantino committed grave abuse of discretion in acquitting the accused in Criminal Case F-162779: The Court held that the respondent judge did not commit grave abuse of discretion. The judge meticulously examined the evidence and provided a detailed explanation for his decision to acquit. The judge found the accused's version of the incident, which involved the complainant's own inebriated state leading to a misunderstanding and subsequent altercation, to be more credible. The complainant's medical certificate indicated alcoholic breath, contradicting his claim of only a small sip of liquor, and suggesting he was in an inebriated state that affected his movements and judgment. The judge also noted inconsistencies in the complainant's testimony regarding his activities before the incident and the lack of evidence supporting the claim that the accused had confederates. The judge's reasoning, based on the evidence presented and the credibility of the witnesses, demonstrated a careful exercise of judicial discretion rather than a capricious or arbitrary act. Therefore, the administrative complaint lacked legal foundation, and the judge could not be held liable for grave abuse of discretion, as his actions were not corrupt nor in persistent disregard of well-known legal rules, citing the principle established in In re Horilleno.
Main Doctrine
The Supreme Court affirmed that a judge's decision to acquit an accused, based on a thorough evaluation of evidence and a detailed explanation of why the accused's version of events was found more credible than the complainant's, does not amount to grave abuse of discretion. The Court emphasized that such a decision, when meticulously reasoned and supported by the evidence on record, falls within the judge's sound discretion and cannot be deemed arbitrary or capricious.