Heirs of Reyes v. Demetria
REITERATIONFacts
The Antecedents: Complainants, heirs of the late Justice Jose B. L. Reyes and Dr. Edmundo A. Reyes, filed an administrative complaint against Justices Demetrio G. Demetria, Ramon A. Barcelona, and Roberto A. Barrios, and Court of Appeals employees Atty. Teresita R. Marigomen and Mr. Efren R. Rivamonte. The complaint stemmed from an ejectment case filed by complainants against Metro Manila Builders, Inc. (Manila Builders) for breach of a lease agreement. The Metropolitan Trial Court (MTC) ruled in favor of the complainants, ordering eviction. Manila Builders appealed, but their appeal was dismissed. Subsequently, Manila Builders filed a petition for certiorari and mandamus with the Court of Appeals (CA) questioning the Regional Trial Court's denial of injunctive relief. On March 23, 1998, the CA issued a resolution, signed only by Justices Demetria and Barcelona, restraining the enforcement of the MTC's writ of execution. Later, on August 21, 1998, the CA promulgated a decision setting aside the MTC decision and the RTC orders, and ordering the restoration of the property to Manila Builders. On September 18, 1998, the CA granted Manila Builders' motion for execution pending appeal, adjudging private respondents (complainants) and their counsel guilty of indirect contempt. On September 21, 1998, the CA directed the appointment of a special sheriff to execute the decision, and Mr. Efren R. Rivamonte was appointed and proceeded to evict the complainants. Procedural History: Complainants filed an administrative complaint against the respondent justices and employees of the CA on September 15, 2000, alleging malicious, deliberate, and unlawful issuance of the restraining order and the decision, and the writ of execution pending appeal despite the pendency of their petition with the Supreme Court. Respondents filed their respective comments, asserting good faith and compliance with orders. The Petition: The administrative complaint sought to hold the respondent justices and employees liable for violating provisions of the Code of Judicial Conduct and for knowingly rendering an unjust judgment.
Issue(s)
Whether the CA justices committed gross ignorance of the law and/or gross misconduct in issuing the March 23, 1998 resolution with only two signatures. Whether the CA justices committed gross ignorance of the law and/or gross misconduct in issuing the writ of execution pending appeal despite the pendency of a petition with the Supreme Court. Whether the CA justices and employees knowingly rendered an unjust judgment. Whether the appointment of a special sheriff by the CA was within its authority.
Ruling
The Supreme Court found the submissions of the respondents to be without merit. Justice Demetrio G. Demetria was found guilty of gross misconduct and fined P20,000.00. The complaint against Atty. Teresita R. Marigomen and Mr. Efren R. Rivamonte was dismissed with admonition and warning. Justice Ramon A. Barcelona was absolved of administrative complicity regarding the issuance of the temporary restraining order but was implicated in the execution pending appeal. Justice Roberto A. Barrios was found not to have taken part in the appointment of the special sheriff and was not shown to have acted with bad faith in the certiorari petition. The Court emphasized the duty of judges to avoid any impression of impropriety and to protect the image and integrity of the judiciary.
Ratio Decidendi
On the irregular issuance of the March 23, 1998 resolution: The Court held that the resolution, signed only by two members of the CA Special Fourth Division, was irregular and could not be received for filing or served on the parties. It stated that while a single justice may issue a temporary restraining order, it must be done sparingly and submitted for ratification. Justice Demetria, as ponente, disregarded existing rules of procedure, constituting gross ignorance of the law. Respondent Marigomen, as Division Clerk of Court, should have called the attention of the ponente to the incomplete signatures and should not have released the resolution. On the issuance of execution pending appeal: The Court found it "grossly appalling" that the CA immediately enforced its decision pending appeal, especially since a petition was already filed with the Supreme Court. It clarified that the Court of Appeals has no authority to issue immediate execution pending appeal of its own decision; such power under Rule 39, Section 2(a) of the Revised Rules of Court applies to judgments of the trial court. The Court noted that the CA was furnished a copy of the petition and that petitioners expressly opposed execution pending appeal, yet their protestations were ignored. The resolution itself acknowledged that the decision was not final by referring to "Execution Pending Appeal of the Decision of this Court." On knowingly rendering an unjust judgment: The Court found insufficient evidence of bad faith or ill motive on the part of the justices who concurred in the ponencia regarding the certiorari petition. It stated that at most, there was a lack of deliberation, which does not automatically warrant administrative sanctions in the absence of bad faith, malice, or corrupt purpose. The Court reiterated that erroneous decisions are presumed to be issued in good faith unless proof to the contrary exists. On the appointment of a special sheriff: The Court declared that the CA has no authority to appoint a special sheriff or direct its employees to do so. This power is an encroachment on the Supreme Court's authority as the appointing power for all officials and employees of the judiciary. Respondent Rivamonte, while absolved due to reliance on superiors' orders, was warned to be more cautious. The Court noted that Justice Barrios did not take part in this specific resolution.
Main Doctrine
Justices who disregard existing rules of procedure, especially elementary ones, commit gross ignorance of the law. The Court of Appeals has no authority to issue immediate execution pending appeal of its own decision, as such power is vested in trial courts under specific conditions. The appointment of a special sheriff by the Court of Appeals is an encroachment on the Supreme Court's appointing power.