Malabed v. Asis
REITERATIONFacts
The Antecedents: Complainant Adelpha E. Malabed initiated an ejectment and damages case against Spouses Ruben and Delia Cericos. Malabed had acquired a parcel of land from her brother, Conrado Estreller, on which the Cericos had begun constructing a house. Despite Malabed's demands to vacate, the spouses refused to do so, leading to the filing of Civil Case No. 860 with the Municipal Circuit Trial Court (MCTC). Procedural History: The MCTC ruled in favor of Malabed, ordering the defendants to vacate the premises and pay damages and attorney's fees. The Cericos appealed to the Regional Trial Court (RTC), Branch 16, Naval, Biliran, presided over by respondent Judge Enrique C. Asis. Judge Asis affirmed the MCTC decision on January 25, 1999. After denying a motion for reconsideration, Judge Asis issued a Writ of Execution. Subsequently, the Cericos filed a Petition for Relief from Judgment, which Judge Asis granted on August 12, 1999, setting aside his previous decision and ordering a new trial. Malabed's motion for reconsideration of this order was denied. Malabed then filed a petition for certiorari with the Court of Appeals (CA), which annulled Judge Asis's orders granting the petition for relief and denying the motion for demolition, finding the petition for relief to have been filed out of time and the alleged fraud to be intrinsic, not extrinsic. The Petition: Adelpha E. Malabed filed a verified complaint with the Office of the Court Administrator (OCA) charging Judge Asis with violation of Rule 1.02, Canon I of the Code of Judicial Conduct for exhibiting bias and partiality. The complainant alleged that Judge Asis favored the Spouses Cericos because their new counsel, Atty. Meljohn de la Peña, also represented Judge Asis in administrative complaints. She further claimed bias in another case where Judge Asis allegedly reversed an MCTC ruling in favor of her sister because the defendants' counsel was Atty. De la Peña. The OCA recommended a fine for gross ignorance of procedural rules, while an investigating justice recommended exoneration. Ultimately, the Court fined Judge Asis P20,000.00, considering past administrative complaints against him, though it did not adopt the finding of bias and partiality.
Issue(s)
Whether respondent Judge Enrique C. Asis committed gross ignorance of the law or procedure by granting a petition for relief from judgment that was filed out of time. Whether respondent Judge exhibited bias and partiality in handling Civil Case No. B-1016 and another civil case involving the complainant's sister.
Ruling
The Supreme Court found respondent Judge Enrique C. Asis administratively liable for gross ignorance of the law or procedure and ordered him to pay a fine of P20,000.00, with a stern warning against repetition of similar acts. The Court did not find sufficient evidence to hold the respondent Judge liable for bias and partiality.
Ratio Decidendi
On the issue of gross ignorance of the law or procedure: The Court affirmed the OCA's finding that respondent Judge committed gross ignorance of the law or procedure by granting the Petition for Relief from Judgment in Civil Case No. B-1016. The Court of Appeals had previously ruled that the petition was filed out of time, specifically on the 71st day from March 2, 1999, which exceeded the 60-day reglementary period provided under Rule 38 of the Rules of Court. The Court reiterated that the periods fixed by Rule 38 are mandatory and non-extendible, and a judge's failure to observe these basic rules constitutes gross ignorance of the law or procedure. The Court emphasized that ignorance of the law or procedure is the mainspring of justice, and judges are expected to have more than a cursory acquaintance with statutes and procedural rules. The respondent Judge's act of entertaining a petition filed beyond the prescribed period, despite the clear findings of the CA, demonstrated an inexcusable failure to observe basic laws and rules. This error was deemed not merely a simple error of judgment but one that amounted to gross ignorance, especially considering the simplicity of the procedural rule involved. On the issue of bias and partiality: The Court found no sufficient evidence to support the complainant's allegations of bias and partiality against respondent Judge. The complainant's claim that the respondent Judge favored the defendants in Civil Case No. B-1016 because their counsel, Atty. Meljohn De la Peña, represented the respondent Judge in a separate administrative case was found to be speculative. The administrative case where Atty. De la Peña represented the respondent Judge was filed on April 7, 2000, which was subsequent to the respondent Judge's issuance of the assailed orders in Civil Case No. B-1016 on August 12, 1999, and December 20, 1999. Therefore, it was illogical to conclude that the respondent Judge was biased due to this representation. Furthermore, the Court clarified that a reversal of a judge's order by a superior court in a certiorari case, such as the CA's decision in SP 56613, does not automatically connote bias or partiality. Such reversals are remedies for errors of judgment, and unless there is a showing of bad faith, malice, or corrupt purpose, an erroneous judgment is not a ground for administrative action. The Court also noted that the respondent Judge had previously been disciplined for similar administrative offenses, which factored into the imposition of the fine.
Main Doctrine
A judge who grants a petition for relief from judgment that was filed out of time, despite clear procedural rules mandating its dismissal, may be held liable for gross ignorance of the law or procedure. While a reversal of a judge's order by a superior court in a certiorari case does not automatically prove bias or partiality, repeated instances of such errors, especially when coupled with prior administrative sanctions, warrant disciplinary action.