Sta. Maria v. Ubay
REITERATIONFacts
The Antecedents: Quintin R. Sta. Maria, attorney-in-fact for Valeriana R. Sta. Maria in Civil Case C-2052, filed a letter-complaint against respondent Judge Alberto Ubay. The charges included violation of Article X, Section 11 of the 1973 Constitution for promulgating a decision beyond the three-month period, violation of Article 204 of the Revised Penal Code for knowingly rendering an unjust judgment contrary to Supreme Court decisions, and falsification by antedating the decision. The complainant also alleged obstacles to the approval of the Record on Appeal. Procedural History: The complainant later filed another complaint against Atty. Paz G. Palanca, Branch Clerk of Court, for infidelity in custody of records and obstructing the approval of the Record on Appeal. The respondent Judge and Atty. Palanca submitted their comments and supporting documents. The complainant replied to these comments, further elaborating on his charges. The Supreme Court reviewed the letter-complaints, comments, and documentary evidence. The Petition: The complainant sought the disciplinary action against the respondent Judge and Atty. Palanca based on the alleged violations of constitutional and penal provisions, as well as procedural rules.
Issue(s)
Whether the respondent Judge violated Article X, Section 11 of the 1973 Constitution by rendering a decision beyond the three-month period. Whether the respondent Judge knowingly rendered an unjust judgment in violation of Article 204 of the Revised Penal Code. Whether the respondent Judge falsified the decision by antedating it. Whether the respondent Judge and Atty. Palanca placed obstacles to the approval of the Record on Appeal. Whether Atty. Palanca was guilty of infidelity in the custody of judicial records. Whether Atty. Palanca violated the Anti-Graft Law, Anti-Graft and Corrupt Practices Act, Civil Service Law, and tenets of the New Society.
Ruling
The charges against the respondent Judge were dismissed for lack of sufficient basis. Atty. Paz G. Palanca was admonished to exercise closer supervision over her subordinates, with a warning of more severe action for future inaction. The other charges against Atty. Palanca were also dismissed.
Ratio Decidendi
On the alleged violation of Article X, Section 11 of the 1973 Constitution: The Court held that the respondent Judge did not violate the constitutional provision. The case was submitted for decision on April 17, 1973, and the decision was signed and filed with the Branch Clerk of Court on July 14, 1973. Citing Ago vs. Court of Appeals and subsequent cases, the Court reiterated that the filing of the signed decision with the clerk of court constitutes rendition of judgment. Therefore, the decision was rendered within the three-month period, even though its promulgation was deferred to August 8, 1973, to allow the judge to further consider certain aspects. The Court affirmed the inherent power of judges to control their processes and amend judgments before they become final. On the charge of knowingly rendering an unjust judgment (Article 204, Revised Penal Code): The Court found no sufficient basis to hold the respondent Judge liable. The Court reiterated that for a judge to be liable under this article, it must be shown beyond doubt that the judgment is unjust (contrary to law or unsupported by evidence) and was rendered with conscious and deliberate intent to do injustice. Delving into the merits of Civil Case C-2052 to determine if the judgment was unjust would encroach upon the appellate jurisdiction of the Court of Appeals. The complainant failed to provide positive evidence of bad faith or a deliberate intent to commit injustice on the part of the respondent Judge. On the charge of falsification by antedating the decision: This charge was rejected as a consequence of the finding that the decision was rendered within the three-month period. Furthermore, the submission of the respondent Judge's Certificates of Service and Monthly Reports for July and August 1973, with stamped dates of receipt by the Judicial Reports Section, contradicted the complainant's assertion that these documents were not submitted. On the alleged obstacles to the approval of the Record on Appeal: The Court found the explanation for the delay in the approval of the Record on Appeal satisfactory. Atty. Palanca explained that motions for time to proofread and an opposition were filed, leading to orders for amendments and subsequent reconsideration. The Court concluded that the complainant had no valid cause to charge the respondent Judge and Atty. Palanca with obstructing the approval of the Record on Appeal. On the charge of infidelity in the custody of judicial records against Atty. Palanca: While Atty. Palanca did not deny the loss or misplacement of a pleading, her explanation, supported by an affidavit of a court employee, was deemed insufficient. The Court held that Atty. Palanca, as Branch Clerk of Court, was remiss in her supervision of her subordinate and could not be held entirely blameless for the loss or misplacement of the pleading. On the alleged violations of the Anti-Graft Law, Anti-Graft and Corrupt Practices Act, Civil Service Law, and tenets of the New Society against Atty. Palanca: The Court found this charge deserved no serious consideration. The complainant failed to specify the provisions violated, failed to particularize the allegations, and did not substantiate the charge. The Court noted that this charge was raised for the first time in a later letter.
Main Doctrine
The filing of a signed decision with the clerk of court constitutes rendition of judgment. A judge has the inherent power to amend and control processes and orders to make them conform to law and justice before a judgment becomes final. To hold a judge liable for knowingly rendering an unjust judgment, it must be shown that the judgment is contrary to law or unsupported by evidence, and was made with conscious and deliberate intent to do injustice.