Bengzon v. Adaoag
REITERATIONFacts
1. The Antecedents: This case stems from an ejectment suit filed by Dr. Luis C. Bengzon and his wife against Eustaquia Sadiamora-Fernandez and Cristy Fernandez. The defendants contested the Municipal Trial Court's (MTC) jurisdiction, alleging the case was a tenancy matter. Despite the MTC's denial of this motion and a subsequent judgment in favor of the Bengzons, the defendants refused to vacate, citing ongoing litigation at the Department of Agrarian Reform Adjudication Board (DARAB) concerning land ownership and tenancy. A Temporary Restraining Order (TRO) was issued by the DARAB, enjoining the ejection. 2. Procedural History: Following the judgment in the ejectment case and the issuance of a writ of execution, the defendants' continued refusal to vacate led Dr. Bengzon to file a motion for demolition of their house. The MTC judge initially set the motion for hearing but retired before resolving it. The case was then transferred to respondent Judge Luisito Adaoag, who held the resolution of the demolition motion in abeyance pending the outcome of the tenancy case before the DARAB. Dr. Bengzon's motion for reconsideration was denied, prompting the filing of this administrative complaint against Judge Adaoag. 3. The Petition: Dr. Bengzon filed an administrative complaint against Judge Adaoag, accusing him of ignorance of the law, incompetence, bias, hostility, persecution, harassment, obstruction of justice, and abuse of authority. The core of the complaint is Judge Adaoag's decision to hold the demolition motion in abeyance, which Dr. Bengzon argued was an improper cognizance of issues already decided and a manifestation of bias. However, the Office of the Court Administrator recommended dismissal, noting that Dr. Bengzon had already filed a petition for certiorari with the Regional Trial Court (RTC) to challenge Judge Adaoag's resolution, making the administrative remedy premature. The Supreme Court concurred, emphasizing that any error in the judge's resolution, if indeed erroneous, would constitute at most an error of jurisdiction or grave abuse of discretion, to be determined by the RTC, not through an administrative complaint.
Issue(s)
Whether the respondent judge committed ignorance of the law, incompetence, bias, hostility, persecution, harassment, and abuse of authority by holding in abeyance the resolution of the complainant's motion for demolition. Whether the administrative complaint is premature given that the assailed resolution is pending review in the Regional Trial Court via a petition for certiorari.
Ruling
The Supreme Court dismissed the administrative complaint for lack of merit. It concurred with the recommendation of the Office of the Court Administrator that the case be dismissed as premature because the assailed resolution of the respondent judge was already pending review in the Regional Trial Court through a petition for certiorari filed by the complainant. The Court found no basis to hold the respondent judge guilty of the administrative charges, stating that while his resolution might be erroneous, it could at most amount to an error of jurisdiction or grave abuse of discretion, which must be determined in the certiorari case.
Ratio Decidendi
On the issue of whether the respondent judge committed ignorance of the law, incompetence, bias, hostility, persecution, harassment, and abuse of authority by holding in abeyance the resolution of the complainant's motion for demolition: The Court held that the administrative complaint should be dismissed because the complainant's proper remedy was judicial, not administrative, especially since he had already filed a petition for certiorari with the RTC. The Court found no basis for the administrative charges, stating that even if the respondent judge's resolution suspending judgment on the motion for demolition was erroneous, it could at most amount only to an error of jurisdiction, which is termed "grave abuse of discretion" under Rule 65, §1 of the Rules of Court. To warrant a finding of ignorance of the law and abuse of authority, the error must be "so gross and patent as to produce an inference of ignorance or bad faith or that the judge knowingly rendered an unjust decision." The Court noted that the respondent judge issued his resolution based on his findings that Romeo Fernandez, who owned the house, was not a party to the ejectment case, possessed a Certificate of Land Transfer for a portion of the land, and had a pending tenancy case before the DARAB with a TRO. Given these facts, the Court found that the respondent judge did not act with patent abuse of authority or in gross ignorance of the law in suspending proceedings. The Court emphasized that holding a judge administratively accountable for every erroneous ruling would be intolerable harassment. On the issue of whether the administrative complaint is premature given that the assailed resolution is pending review in the Regional Trial Court via a petition for certiorari: The Court affirmed the recommendation of the Office of the Court Administrator (OCA) to dismiss the complaint for being premature. The Court stated that the complainant's remedy was judicial, not administrative, and since he had already filed a petition in court for the annulment of the order he questioned, the Court concurred with the OCA's recommendation. The Court reiterated that the dismissal was not based on a finding that the resolution suspending action on the motion for demolition was correct, but on the fact that whether the resolution should be set aside for having been issued in excess of jurisdiction or with grave abuse of discretion must be determined in the certiorari case filed with the RTC. The Court concluded that there was no basis for finding the respondent guilty of the administrative charges leveled against him.
Main Doctrine
An administrative complaint against a judge for alleged ignorance of law or abuse of authority in issuing a resolution will be dismissed if the assailed resolution is already pending review in a higher court via a petition for certiorari, as the judicial remedy is the proper avenue to determine if the resolution was issued with grave abuse of discretion.