Maylas v. Sese
REITERATIONFacts
The Antecedents: Complainant Ignacio E. Maylas, Jr. charged respondent Judge Manuel L. Sese with gross ignorance of the law, incompetence, and violation of the Rules of Court in connection with Criminal Case No. 10911. The accused in said criminal case filed a Motion to Quash on the ground that the facts alleged do not constitute an offense. Procedural History: Respondent judge granted the motion to quash not on the ground alleged by the accused but on lack of probable cause. The public prosecutor's motion for reconsideration was denied. A petition for certiorari was filed before the Court of Appeals, which annulled and set aside the assailed orders, reinstated Criminal Case No. 10911, and directed the Regional Trial Court to continue with the proceedings. The Petition: The administrative complaint was filed against respondent judge.
Issue(s)
Whether respondent judge committed gross ignorance of the law, incompetence, and willful disregard of the Rules of Court. Whether an error of judgment in the exercise of adjudicative functions is a ground for administrative sanction.
Ruling
The administrative case against Judge Manuel L. Sese is DISMISSED for lack of merit.
Ratio Decidendi
On whether respondent judge committed gross ignorance of the law, incompetence, and willful disregard of the Rules of Court: The Court found that the error attributed to respondent judge pertained to the exercise of his adjudicative functions. As a matter of policy, the acts of a judge in his official capacity are not subject to disciplinary action in the absence of fraud, dishonesty, and corruption. He cannot be subjected to liability, civil, criminal, or administrative, for any of his official acts, no matter how erroneous, as long as he acts in good faith. Only judicial errors tainted with fraud, dishonesty, gross ignorance, bad faith, or deliberate intent to do an injustice will be administratively sanctioned. The Court noted that the Court of Appeals found the error in issuing the assailed Order to be tantamount to grave abuse of discretion. However, grave abuse of discretion alone is not a ground for disciplinary proceedings. The filing of an administrative complaint is not the proper remedy when a sufficient judicial remedy exists, such as a petition for certiorari. On whether an error of judgment in the exercise of adjudicative functions is a ground for administrative sanction: The Court reiterated the settled rule that errors committed by a judge in the exercise of his adjudicative functions cannot be corrected through administrative proceedings but should be assailed through judicial remedies. Section 2, Rule 117 of the Rules of Court mandates that in a motion to quash, the court shall not consider any ground other than those stated in the motion, except lack of jurisdiction over the offense charged. Respondent judge erred when he considered a ground not raised by the accused. However, even granting that the respondent judge erred, he could not be held administratively liable considering that there was no proof that such error of judgment was tainted with bias or partiality, fraud, dishonesty, bad faith, or deliberate intent to do an injustice. To merit disciplinary action, the error or mistake must be gross or patent, malicious, deliberate, or in bad faith. In the absence of a showing to the contrary, a defective or erroneous decision or order is presumed to have been issued in good faith. The complaint did not impute malice or bad faith, and the respondent claimed careful examination of the records.
Main Doctrine
Errors committed by a judge in the exercise of his adjudicative functions, even if erroneous and amounting to grave abuse of discretion, are not administratively sanctionable in the absence of fraud, dishonesty, corruption, malice, bad faith, or deliberate intent to do injustice. Such errors should be corrected through available judicial remedies.