Villamor v. Salas
REITERATIONFacts
The Antecedents: Civil Case No. B-398 for recovery of ownership of a parcel of land was filed by Gloria Naval against George Carlos and was raffled to Judge Adriano Villamor. Criminal Cases Nos. N-989 to N-993 for qualified theft were filed by Carlos against Naval and her helpers, also assigned to Judge Villamor. The criminal cases were archived due to the pendency of the civil case. After trial, Judge Villamor ruled in favor of Naval in the civil case, declaring her the lawful owner and possessor and ordering Carlos to vacate. Subsequently, Judge Villamor dismissed the criminal cases against Naval and her helpers, citing the decision in the civil case. Judge Villamor also granted execution pending appeal of his decision in Civil Case No. B-398, which Carlos challenged unsuccessfully. Procedural History: Carlos filed an administrative case (A.M. No. RTJ-87-105) against Judge Villamor for issuing illegal orders and an unjust decision in Civil Case No. B-398. This Court summarily dismissed the administrative case. Undeterred, Carlos filed a civil action for damages (Civil Case No. CEB-6478) against Judge Villamor, alleging he knowingly rendered an unjust judgment by dismissing the criminal cases. Instead of answering, Judge Villamor issued an order of direct contempt against Carlos and his lawyer, Attorney Antonio T. Guerrero, for using derogatory language, sentencing them to five days imprisonment and a P500 fine. This contempt order was challenged by Carlos in this Court (G.R. Nos. 82238-42), which restrained Judge Villamor and later annulled the contempt order. The trial court dismissed Civil Case No. CEB-6478 for lack of jurisdiction, which was affirmed by the Court of Appeals and this Court. Subsequently, Carlos and Attorney Guerrero filed separate complaints for damages against Judge Villamor for allegedly rendering an unjust order of contempt. Attorney Guerrero's complaint (Civil Case No. CEB-8802) was raffled to Judge Peary G. Aleonar, and Carlos' complaint (Civil Case No. CEB-8823) was raffled to Judge Bernardo LL. Salas. Judge Villamor's motions to dismiss these cases were denied by both respondent judges. The Petition: Judge Villamor filed petitions for certiorari and prohibition with restraining orders against Judges Aleonar and Salas, praying for the dismissal of the damages cases filed against him, arguing that the respondent judges could not take cognizance of actions for damages against a co-equal judge for an order that was subsequently annulled by the Supreme Court.
Issue(s)
Whether respondent Judges Aleonar and Salas may take cognizance of the actions for damages against Judge Villamor for allegedly having rendered an unjust order of direct contempt which this Court subsequently annulled. Whether a Regional Trial Court may review and declare as unjust a judgment or order of a co-equal Regional Trial Court and hold the judge thereof liable for damages.
Ruling
The petitions for certiorari are GRANTED. Civil Cases Nos. CEB-8802 and CEB-8823, pending in the salas of respondents Judge Peary G. Aleonar and Judge Bernardo LL. Salas, are hereby dismissed. The temporary restraining orders issued by this Court in these cases are made permanent.
Ratio Decidendi
On the issue of whether respondent Judges Aleonar and Salas may take cognizance of the actions for damages against Judge Villamor: The Supreme Court held that no Regional Trial Court can pass upon and scrutinize, and much less declare as unjust, a judgment or order of another Regional Trial Court and sentence the judge thereof liable for damages. This is because only higher appellate courts, namely the Court of Appeals and the Supreme Court, are vested with the authority to review and correct errors of the trial courts. To allow respondent judges to proceed would permit a court to review and interfere with the judgment of a co-equal court over which it has no appellate jurisdiction or power of review. The various branches of the Regional Trial Court are co-equal and may not interfere with each other's cases, judgments, and orders. On the issue of whether a Regional Trial Court may review and declare as unjust a judgment or order of a co-equal Regional Trial Court: The Court reiterated that only after an Appellate Court, in a final judgment, has found that a trial judge's errors were committed deliberately and in bad faith may a charge of knowingly rendering an unjust decision be leveled against the latter. In the present case, the Supreme Court's decision annulling Judge Villamor's order of direct contempt did not contain any declaration that the erroneous order was rendered maliciously or with conscious and deliberate intent to commit an injustice. The Court noted that a previous order of direct contempt issued by Judge Villamor against Carlos' former counsel was sustained by this Court, indicating that such orders were not inherently unjust. At most, the annulled order of direct contempt could only be considered an error of judgment for which Judge Villamor may not be held criminally or civilly liable to the respondents. A judge is not liable for an erroneous decision in the absence of malice or wrongful conduct in rendering it.
Main Doctrine
Regional Trial Courts cannot pass upon and scrutinize, much less declare as unjust, a judgment or order of a co-equal Regional Trial Court and hold the judge thereof liable for damages, as only higher appellate courts possess the authority to review and correct errors of trial courts. A judge is not liable for an erroneous decision in the absence of malice or wrongful conduct in rendering it.