Crisologo v. Daray
REITERATIONFacts
The Antecedents: Complainant Jesus G. Crisologo charged respondent Judge Marivic Trabajo Daray with Gross Misconduct, Undue Delay in Rendering a Decision or Order, and Gross Ignorance of the Law of Procedure. The charges stemmed from the denial of complainant's Motion for Intervention in two consolidated civil cases (Civil Case Nos. 3220 and 3387) concerning properties that complainant claimed were ancestral and co-owned by him and his siblings. The original parties to the civil cases, Marina Crisologo, Jr., Salvador Crisologo, Victor Callao, and Rural Bank of Tagum, Inc. (RBTI), submitted a Compromise Agreement on January 22, 2004, ceding ownership of the subject land to RBTI. Complainant and his sister Carolina C. Abrina moved to intervene on February 13, 2004, asserting their proprietary rights as co-owners. Respondent Judge, acting as Presiding Judge, denied the Motion for Intervention on August 23, 2004, stating that intervention would unduly delay adjudication and that complainant's claims could be pursued in a separate case. Complainant's motion for reconsideration was denied on October 15, 2004, for lack of notice of hearing. A decision approving the compromise agreement was issued on October 27, 2004. Copies of both the denial of reconsideration and the decision were inadvertently sent to complainant's previous counsel, Atty. Rodolfo Ta-asan, instead of his current counsel, Atty. Jenette Marie Crisologo, leaving complainant unaware of these developments. Procedural History: Upon learning of RBTI's motion for execution on November 4, 2004, complainant filed an Urgent Manifestation and Notice of Appeal on November 8, 2004, and an Urgent Motion for Voluntary Inhibition of respondent Judge. When the respondent Judge failed to act on the notice of appeal, complainant filed a petition for certiorari, prohibition, and mandamus with the Court of Appeals (CA) on December 7, 2004. The respondent Judge inhibited herself on December 8, 2004, but refrained from acting on the notice of appeal. The notice of appeal was eventually acted upon by the new presiding judge on March 15, 2005. The CA rendered a Decision on July 20, 2006, finding grave abuse of discretion in the denial of the motion for intervention. The Petition: The complainant filed an administrative complaint against the respondent Judge. The Investigating Justice of the CA recommended that the respondent be fined for undue delay and gross ignorance of the law. The Supreme Court, however, reviewed the findings and recommendations.
Issue(s)
Whether the respondent Judge committed Gross Misconduct by failing to furnish the complainant's counsel of record with copies of court processes. Whether the respondent Judge committed Undue Delay in rendering a decision or order. Whether the respondent Judge committed Gross Ignorance of the Law or Procedure in denying the Motion for Intervention.
Ruling
The administrative case against Judge Marivic Trabajo Daray is DISMISSED.
Ratio Decidendi
On the charge of Gross Misconduct: The Court found that the failure to furnish the complainant's new counsel of record with copies of the court's processes was unintentional and due to an honest oversight by court personnel. This omission, while regrettable, did not amount to gross misconduct as there was no clear showing of bad faith. The respondent Judge's explanation that copies were inadvertently sent to the previous counsel was accepted as a mitigating factor, absolving her from administrative liability on this ground. The Court reiterated that judges are not administratively liable for erroneous judicial acts performed in good faith. On the charge of Undue Delay: The Court noted that the complainant filed a motion for voluntary inhibition on the same day he filed his notice of appeal. The respondent Judge inhibited herself from the case on the 30th day after the notice of appeal was filed. From the time of inhibition, the respondent Judge could no longer perform any act pertaining to the complainant's appeal, as this duty devolved upon her successor. Therefore, the respondent Judge should not be sanctioned for her failure to act on the notice of appeal after she had inhibited herself from the case. The Court emphasized that the filing of an administrative complaint is not the proper remedy when a sufficient judicial remedy exists. On the charge of Gross Ignorance of the Law or Procedure: The Court held that the allowance or disallowance of a motion to intervene is addressed to the sound discretion of the court. The respondent Judge's denial of the motion for intervention was based on valid considerations, namely, that intervention would unduly delay the adjudication of the rights of the original parties, who had been litigating for almost a decade, and that the complainant's claims could be better protected in a separate action. The respondent Judge sincerely believed that this was the proper course of action, and there was no showing that she was motivated by ill-will. Therefore, she could not be sanctioned for denying the motion for intervention, as she acted in good faith and within the bounds of her discretion. The Court reiterated that to constitute gross ignorance of the law, the erroneous act must be attended by bad faith, fraud, dishonesty, or corruption.
Main Doctrine
Judges are not administratively liable for erroneous judicial acts performed in good faith. However, inexcusable failure to observe basic laws and rules, especially when simple and elementary, constitutes gross ignorance of the law, but must be attended by bad faith, fraud, dishonesty, or corruption. The allowance or disallowance of a motion to intervene is addressed to the sound discretion of the court, and valid considerations include preventing undue delay.