Francisco v. Corcuera
MODIFICATIONFacts
The Antecedents: Complainant Judge Pablo B. Francisco filed an administrative complaint against respondent Judge Hilario F. Corcuera. The complaint stemmed from respondent Judge Corcuera's order granting a new trial in Land Registration Case No. B-568, previously denied by complainant Judge Francisco when he was the Acting Presiding Judge of RTC-Br. 25, Biñan, Laguna. SCIENCE PARK of the Philippines, Inc., sought registration of five parcels of land claimed to be accretions to its property, but the application was denied by complainant Judge Francisco. After complainant Judge Francisco was relieved and respondent Judge Corcuera returned to his permanent station at RTC-Br. 25, respondent Judge Corcuera granted SCIENCE PARK's motion for new trial. Procedural History: Complainant Judge Francisco advised respondent Judge Corcuera that under SC Adm. Circ. No. 5-98, motions for new trial filed after a decision should be resolved by the Acting Presiding Judge who penned the original decision. Despite this, complainant Judge Francisco issued a contrary order denying the motion for new trial. Subsequently, respondent Judge Corcuera rendered a decision granting SCIENCE PARK's application. The Petition: Complainant Judge Francisco suspected respondent Judge Corcuera of conspiracy to harass him and facilitate the land registration for SCIENCE PARK. Respondent Judge Corcuera explained that complainant Judge Francisco was already bereft of authority to entertain the motion for new trial after being transferred. The Court Administrator found respondent Judge Corcuera guilty of violating Sec. 2 of Adm. Circ. 5-98, recommending a fine and warning.
Issue(s)
Whether respondent Judge Corcuera committed gross misconduct in granting the motion for new trial. Whether respondent Judge Corcuera violated Section 2 of Administrative Circular No. 5-98.
Ruling
The complaint against respondent Judge Hilario F. Corcuera is DISMISSED. Respondent Judge is exonerated of the charge. Complainant Judge Pablo B. Francisco is severely REPRIMANDED for conduct unbecoming a judge.
Ratio Decidendi
On Whether respondent Judge Corcuera committed gross misconduct in granting the motion for new trial: The Supreme Court held that for a charge of gross misconduct to prosper, it must be shown that the judicial act complained of was corrupt, inspired by an intention to violate the law, or in persistent and intentional disregard of well-known legal rules. The Court found no evidence that respondent Judge Corcuera acted whimsically, capriciously, maliciously, or without jurisdiction in granting the motion for new trial. A permanent presiding judge possesses full authority over cases in their station, and Administrative Circular No. 5-98 does not divest them of this authority regarding motions for new trial or reconsideration filed after a decision by a former acting/assisting judge. The decision on who rules on such motions rests with the permanent presiding judge. The records did not show any bias or partiality against respondent Judge Corcuera, nor was he wanting in power or authority to rule on the motion. The Court emphasized that it would not inquire into the correctness of a judge's decision if exercised within their jurisdiction. On Whether respondent Judge Corcuera violated Section 2 of Administrative Circular No. 5-98: The Court acknowledged that the case Mabunay was promulgated after the controversy arose and thus could not be applied retroactively. However, the Court reiterated the reminder in Mabunay regarding the procedure for judges to decide cases they substantially heard in other stations. The Court clarified that Administrative Circular No. 5-98 grants authority to acting/assisting judges to decide motions for reconsideration and new trial only if the permanent presiding judge chooses not to act on them, or if there is prior conformity from the permanent presiding judge. Crucially, once the permanent presiding judge has acted on a case or ruled on an incident, the acting/assisting judge loses such authority and cannot issue a contrary order. The Court found that respondent Judge Corcuera acted within his authority as the permanent presiding judge of RTC-Br. 25 when he granted the motion for new trial, as complainant Judge Francisco had already been relieved of his detail thereat. The Court also noted that complainant Judge Francisco was aware of respondent Judge Corcuera's order granting the new trial.
Main Doctrine
A permanent presiding judge has full authority over all cases pending in their official station. Administrative Circular No. 5-98 should not be construed to deprive a permanent presiding judge of their authority to rule on motions for new trial and reconsideration of decisions rendered by a former acting/assisting judge. The decision on who between the permanent presiding judge and the acting/assisting judge would rule on a pending motion for reconsideration or new trial is lodged in the hands of the permanent presiding judge.