Ang v. Quilala
REITERATIONFacts
The Antecedents: Complainant Benito Ang was charged with estafa involving P3,185,276.00 and 22 counts of violating Batas Pambansa Blg. 22. Ang failed to appear for his arraignment on the BP 22 charges before the Metropolitan Trial Court (MeTC) of Manila, Branch 26, prompting the respondent judge to issue a warrant for his arrest and order the forfeiture of his surety bond. Procedural History: Following the issuance of the arrest warrant, Ang filed a motion to lift it. He alleged that Clerk III Louie Macabeo solicited P30,000.00 from him for assistance. Ang's subsequent motion for reconsideration and/or to lift the arrest order was denied by respondent Judge Reinato G. Quilala. Ang's counsel attempted to file another motion for reconsideration on the same day the warrant was served, but this was also denied by the judge. The case was then referred to the Office of the Court Administrator (OCA) for evaluation, which recommended the dismissal of the administrative case. The Petition: Benito Ang filed a verified complaint against Judge Reinato G. Quilala, Clerk of Court Zenaida Reyes-Macabeo, and Clerk III Louie Macabeo, charging them with extortion. Ang alleged that the respondents acted in concert to extort money from him in relation to his criminal cases. The Supreme Court, in its resolution, reviewed the findings of the OCA and the arguments presented by both parties. The Court ultimately dismissed the administrative complaint for lack of merit, finding no concrete evidence of extortion or any gross, deliberate, or malicious intent on the part of the respondents in their judicial actions.
Issue(s)
Whether the respondent judge committed administrative offenses in denying the complainant's motions for reconsideration and in issuing the warrant of arrest. Whether the respondent court personnel committed extortion.
Ruling
The administrative complaint against Judge Reinato G. Quilala, Clerk of Court Zenaida Reyes-Macabeo, and Clerk III Louie Macabeo is DISMISSED for lack of merit.
Ratio Decidendi
On the administrative liability of the respondent judge: The Court reiterated the settled doctrine that judges are not administratively liable for errors of judgment made in the exercise of their judicial functions, provided they act within their legal powers and jurisdiction. The denial of the complainant's first motion for reconsideration, based on his failure to attend the arraignment due to alleged indisposition, was within the respondent judge's discretion and constituted an error of judgment, not an administrative offense. Similarly, the denial of the second urgent motion for reconsideration was justified because it lacked proof of service on the Prosecutor's Office and had no legal basis, as the reinstatement of the original bailbond was proper. The record did not show any ill-will, bad faith, or malicious intent on the part of the respondent judge. Bad faith requires a dishonest purpose, moral obliquity, or conscious doing of a wrong, which was not proven by the complainant. The alleged errors were not gross or patent, and there was no showing of deliberate or malicious intent to cause prejudice. On the charge of extortion against court personnel: The Court found no proof presented by the complainant against the Clerk of Court and the Clerk III to substantiate the charge of extortion. The respondents vehemently denied the allegations, with Zenaida Reyes-Macabeo stating she merely released the warrant signed by the judge and had no control over judicial processes. Louie Macabeo asserted it was impossible for him to solicit money from someone he barely knew and that he could not assure favorable action on a motion. Therefore, the dismissal of the administrative charge against them was deemed proper.
Main Doctrine
Judges are not administratively liable for errors of judgment made in the exercise of their judicial functions, provided they act within their legal powers and jurisdiction, unless the error is gross, patent, deliberate, malicious, or incurred with evident bad faith.