Bartido v. Larrobis
REITERATIONFacts
The Antecedents: Complainant Crispin Bartido charged Municipal Judge Cesar C. Larrobis with alleged partiality and deliberately ignoring Presidential Decree No. 20 in deciding an ejectment case (Civil Case No. R107). The complainant's sister was the plaintiff in the ejectment case. Procedural History: The complainant alleged that the respondent judge considered the defendant's land rental receipt, paid after the property was redeemed, as proof of open occupation, while rejecting the plaintiff's rental receipts based on a lease contract as "Post Litem Motam." A motion for reconsideration, arguing the decision was contrary to law and Presidential Decree No. 20, was denied. The respondent judge was required to comment and did so. The case was referred to the Executive Judge of the Court of First Instance of Cebu for investigation. During the investigation, the complainant failed to appear twice, despite due notice, leading the respondent judge to move for dismissal or submission of the case based on his comments. The Executive Judge found the charges to be mere conclusions of the complainant and considered them as errors of judgment, the remedy for which is appeal, not an administrative case. The Executive Judge also noted that an additional charge of dishonesty in the rejoinder was unverified and that supporting affidavits were hearsay. It was also noted that the decision of the respondent judge in the ejectment case was reversed by the Court of First Instance, and the decision had already been executed. The Petition: This is an administrative complaint filed against Municipal Judge Cesar C. Larrobis for alleged partiality and deliberate ignorance of the law in deciding an ejectment case. The complainant argued that the judge's decision was contrary to law, specifically Presidential Decree No. 20, and that the denial of the motion for reconsideration further demonstrated this ignorance.
Issue(s)
Whether the respondent judge committed partiality and deliberately ignored Presidential Decree No. 20 in deciding Civil Case No. R107. Whether the errors of judgment, if any, committed by the respondent judge in the ejectment case warrant administrative sanctions.
Ruling
The complaint is DISMISSED for lack of merit.
Ratio Decidendi
On Issue 1: The Court found that the charges of partiality and deliberately ignoring the law were mere conclusions of the complainant. Even if true, these were considered mere errors of judgment in deciding the ejectment case. The proper remedy for such errors is by appeal, not by filing an administrative case against the respondent judge. The respondent judge's explanation by way of denial was considered well-taken. Furthermore, an additional charge of dishonesty made in the rejoinder was unverified, and the affiants were not presented, rendering their affidavits as inadmissible hearsay evidence. The reversal of the respondent judge's decision by the Court of First Instance, while noted, did not alter the nature of the alleged errors as judicial, not administrative. On Issue 2: The Court affirmed the findings of the Executive Judge that the errors of the respondent judge in the ejectment case were "mere errors of judgment." The Court reiterated that the remedy for rectifying such errors is through appeal. The complainant failed to substantiate his charges despite ample opportunity. Therefore, the administrative complaint was dismissed for lack of merit, as the alleged errors did not rise to the level of administrative liability requiring disciplinary action against the judge.
Main Doctrine
The Supreme Court reiterated that alleged errors of judgment by a judge in deciding a case, such as in an ejectment proceeding, do not constitute grounds for administrative liability. Instead, these alleged errors should be rectified through the appropriate appellate remedies. The Court found that the complainant failed to substantiate his charges of partiality and deliberate ignorance of the law, and that the issues raised were mere conclusions of the complainant. The investigation revealed that the complainant did not present sufficient evidence, and the affidavits submitted were considered hearsay. Consequently, the administrative complaint was dismissed for lack of merit.