Flores v. Abesamis
REITERATIONFacts
The Antecedents: The case originated from a collection suit (Civil Case No. Q-45825) where Rolando R. Ligon sued Damaso S. Flores. A compromise agreement was approved, stipulating that Flores would grant Ligon possession of the Parañaque Cockpit Stadium in case of default. Flores defaulted, and the court issued an order of execution. Flores appealed, arguing the order altered the compromise terms regarding interest computation. Ligon subsequently purchased the cockpit stadium. The trial court granted Ligon's motion for execution pending appeal, placing Ligon in possession. Flores filed a certiorari action, and the Court of Appeals invalidated the order, directing restoration of possession to Flores. This was affirmed by the Supreme Court. Ligon leased the cockpit to a third party. Flores sought execution of the appellate court's judgment, but Ligon filed another certiorari petition, obtaining a temporary restraining order. The Court of Appeals consolidated cases and ruled against Ligon, but he appealed to the Supreme Court. The Supreme Court denied Ligon's petition and lifted the TRO. Flores again sought execution, and Ligon filed yet another certiorari petition, which was rebuffed by the Court of Appeals. Sheriff's attempt to place Flores in possession was again resisted by Ligon. The Regional Trial Court (Branch 85, presided over by Judge Abesamis) issued an order directing the sheriff to desist from enforcing the writ, citing Ligon's acquisition of ownership as justification for retention. Flores' motion for reconsideration was denied by the pairing judge, citing supervening events and Flores' substantial monetary obligation. These orders were challenged by Flores in a certiorari suit before the Court of Appeals, which dismissed his petition. Flores appealed to the Supreme Court. Procedural History: Flores filed administrative complaints against Judge Abesamis and Judge Regino. These complaints were dismissed by the Supreme Court and the Ombudsman for lack of merit. Flores later filed a new affidavit-complaint against Judge Abesamis for violation of R.A. 3019, alleging bias in granting a motion that caused undue injury. This new complaint was referred to the Office of the Court Administrator and docketed as A.M. No. SC-96-1. Judge Abesamis commented, highlighting that the new accusations were based on the same facts and incidents as previous dismissed complaints and that the orders were upheld by appellate tribunals. Flores filed a reply, selectively invoking favorable adjudications. The Petition: This administrative case, A.M. No. SC-96-1, arose from the complaint filed by Damaso S. Flores against Hon. Bernardo P. Abesamis, Regional Trial Court Branch 85, Quezon City (now Deputy Administrator), for alleged violation of R.A. 3019, specifically bias and prejudice in granting a motion which caused undue injury to the complainant. The complaint was based on several orders issued by Judge Abesamis and the pairing judge concerning the execution of a compromise agreement in Civil Case No. Q-45825.
Issue(s)
Whether the administrative complaint against Judge Abesamis is meritorious, considering the prior dismissal of similar charges and the affirmation of his challenged orders by higher courts. Whether the filing of administrative cases against a judge constitutes a valid ground for inhibition, especially when the judge initially proposed inhibition but was prevailed upon by the parties to continue. Whether the concept of 'supervening events' can justify the non-execution of a final and executory judgment.
Ruling
The Supreme Court dismissed the administrative complaint against Judge Bernardo P. Abesamis for utter lack of merit. It further ordered complainant Damaso S. Flores to explain why he should not be disciplined for willful disregard of court judgments and orders, abuse of court processes, and forum shopping.
Ratio Decidendi
On the administrative complaint against Judge Abesamis: The Court found the charges against Judge Abesamis to be utterly without foundation, mirroring those previously rejected by the Supreme Court and the Ombudsman. All the orders issued by Judge Abesamis (and Judge Regino) that Flores branded as improper were reviewed and found to be correct and consistent with facts and law. Specifically, the orders of February 16, 1990, April 16, 1990, and June 6, 1990, were affirmed by the Court of Appeals (CA-G.R. SP No. 22201) and the Supreme Court (G.R. No. 97556). Similarly, Judge Abesamis' orders of June 25, 1990, and December 10, 1990, were sustained by the Court of Appeals (CA-G.R. SP No. 22881) and the Supreme Court (G.R. No. 101152). The Court noted that the new accusations were based on the same facts and incidents as previous dismissed complaints and that the challenged orders had been upheld by appellate tribunals. The Court explicitly stated that the charges were "as utterly without foundation as those already rejected by this Court and the Ombudsman." On the motion for inhibition: The Court found Flores' imputations of bias against Judge Abesamis to be patently without basis. It was noted that Judge Abesamis had initially proposed his own inhibition, but both parties vigorously objected and prevailed upon him to stay in the case, expressing no doubt as to his integrity. The Court pointed out that Flores' alleged loss of faith appeared to stem only from the issuance of an unfavorable order. The Court reiterated the principle that the mere filing of an administrative case against a judge is not a ground for inhibition. On the concept of 'supervening events' and execution of judgment: The Supreme Court, in its consolidated decision in G.R. No. 97556 and G.R. No. 101152, affirmed the Court of Appeals' ruling that the trial court correctly found Flores' right to possess the cockpit stadium to be inefficacious and invalidated by Ligon's substantial right as absolute owner. The Court held that Ligon's purchase of the stadium constituted a "supervening event" that rendered the previously rendered judgment in Flores' favor impossible of execution. This was an exception to the general rule on the immutability of final judgments. The Court reasoned that Flores had a due and demandable obligation to Ligon, and with Ligon having purchased the stadium, there remained no legal or equitable basis for Flores to possess it. The Court explicitly stated, "We consequently hold that, as an exception to the general rule on immutability of final judgments, the supervening event that private respondent has become the owner of the mortgaged premises has rendered the judgment in the main case (earlier rendered in petitioner's favor) impossible of execution."
Main Doctrine
The filing of administrative cases against a judge does not automatically warrant inhibition, especially when the parties themselves initially objected to inhibition, and the subsequent complaints are found to be without merit and based on the same facts previously dismissed.