Flores v. Abesamis
REITERATIONFacts
The Antecedents: Atty. Damaso S. Flores was the defendant in a civil case involving an indebtedness of P1.8 million to Rolando Ligon. A compromise judgment was rendered which provided that in case of default, Flores would surrender the "Parañaque Cockpit Stadium" to Ligon. Following a breach, Judge Abesamis ordered execution. A long-standing legal battle ensued where Flores attempted to regain possession of the cockpit, but his efforts were repeatedly frustrated by Ligon's successful applications for Temporary Restraining Orders (TROs) from the Court of Appeals and the Supreme Court. Procedural History: Despite knowing that Judge Abesamis was legally restrained by higher courts, Flores filed multiple criminal and administrative cases against the Judge in the Office of the Ombudsman (OMB) and the Supreme Court, alleging "deliberate delay," "partiality," and "ignorance of the law." The Ombudsman dismissed the criminal complaint (OMB-0-89-01209) for lack of merit, finding the Judge acted with dispatch. The Supreme Court likewise dismissed the administrative cases (A.M. No. RTJ-89-348 and A.M. No. RTJ-90-505) in 1993. However, in 1995, Flores filed yet another complaint with the Ombudsman (CPL No. 95-3618) based on the same orders that had already been upheld by the Court of Appeals and the Supreme Court. The Petition: The 1995 complaint was referred to the Supreme Court and docketed as A.M. No. SC-96-1. The Court dismissed the complaint for "utter lack of merit" and ordered Flores to show cause why he should not be disciplined for willful disregard of judgments, abuse of process, and forum shopping. Flores, in his compliance, argued that he acted with "pure motive" to obtain justice and did not intend to harass the judges.
Issue(s)
Whether Atty. Flores is guilty of contempt of court for filing multiple unfounded administrative and criminal cases against judges. Whether administrative or criminal actions against judges can serve as a substitute for judicial remedies.
Ruling
Atty. Damaso S. Flores is DECLARED GUILTY of contempt of court and SENTENCED to pay a FINE OF ONE THOUSAND PESOS (P1,000.00).
Ratio Decidendi
On Issue 1: The Court found Atty. Flores guilty of contempt because he instituted criminal and administrative proceedings that he knew were completely without basis in fact. The evidence showed that the delays he complained of were not caused by Judge Abesamis but were the result of judicial restraints (TROs) issued by higher courts. By filing a new complaint in 1995 based on issues already resolved with finality by the Supreme Court in 1993, Flores manifested an insolent disregard for the Court's adjudgments. This conduct constitutes forum shopping of the most blatant sort, as it was a clear attempt to re-litigate issues already passed upon. Such actions are considered an abuse of the process or proceedings of the courts and improper conduct tending to obstruct or degrade the administration of justice under Rule 71, Section 3 of the Rules of Court. On Issue 2: The Court emphasized that disciplinary proceedings and criminal actions against judges are not complementary or suppletory of, nor a substitute for, judicial remedies. The law provides ample judicial remedies—such as motions for reconsideration, appeals, and special civil actions like certiorari—to correct errors or irregularities committed by a trial court. Resort to and exhaustion of these judicial remedies are absolute pre-requisites before any administrative or criminal inquiry into a judge's liability can begin. Judges must be free to perform their duties without the fear of civil, criminal, or administrative sanctions for acts done within the scope of their jurisdiction and in good faith. Prosecution of a judge can only occur if there is a final declaration by a competent court of the manifestly unjust character of the challenged order, coupled with evidence of malice, bad faith, or inexcusable negligence. Flores' premature and repetitive filings violated these principles and were intended to intimidate the respondent judges.
Main Doctrine
Disciplinary proceedings and criminal actions against Judges are not complementary or suppletory of, nor a substitute for, judicial remedies. Resort to and exhaustion of these judicial remedies, as well as the entry of judgment in the corresponding action or proceeding, are pre-requisites for the taking of other measures against the persons of the judges concerned, whether of civil, administrative, or criminal nature. It is only after the available judicial remedies have been exhausted and the appellate tribunals have spoken with finality, that the door to an inquiry into his criminal, civil or administrative liability may be said to have opened, or closed.