Khanna v. Delos Santos
REITERATIONFacts
The Antecedents: Dolora Cadiz Khanna (Khanna) filed a verified complaint against Associate Justices of the Court of Appeals (CA), a Regional Trial Court (RTC) judge, a Metropolitan Trial Court (MeTC) judge, and a Sheriff III, charging them with corruption and extortion. Khanna alleged that she and her husband purchased parcels of land in 2007, developing them into a luxury resort. Subsequently, Atty. Lucas Licerio and his cohorts allegedly began harassing them by filing numerous Estafa cases. Khanna filed a Petition for Injunction with prayer for TRO against Atty. Licerio before the RTC, Branch 4, Kalibo, Aklan, presided over by Judge Ronald H. Exmundo. Khanna alleged that Judge Exmundo instructed her to hire Atty. Mateo C. Hachuela and to give ₱300,000.00 for the TRO, which she complied with. A TRO was issued, and Khanna and her husband regained possession. Later, Atty. Licerio allegedly forcibly took over the property without a court order. Khanna claimed Atty. Licerio paid Judge Exmundo to rule in his favor, and that Atty. Hachuela and Judge Exmundo traveled to Hong Kong. Judge Exmundo subsequently denied Khanna's Petition for Injunction and her Motion for Reconsideration. Atty. Licerio filed a Motion for Execution Pending Appeal, and Atty. Hachuela allegedly demanded ₱1,000,000.00, which Khanna paid via two checks. Atty. Licerio then filed a Motion for Execution Pending Appeal before the CA, which was granted by the 19th Division of the CA, composed of Associate Justices Edgardo L. Delos Santos, Marilyn B. Lagura-Yap, and Jhosep Y. Lopez. Khanna alleged that the CA justices disregarded her objections and issued the resolution without basis. Khanna claimed that she, her husband, and an NBI friend met with Judge Fricia C. Gomez-Guillen, her husband Miller Guillen, and Sheriff Juan S. Apolinar. They allegedly discussed Khanna's CA case, and the group offered assistance for a favorable ruling. Subsequent phone calls indicated the CA justices were asking for ₱12,000,000.00 to lift the writ of execution and issue a permanent injunction. Miller Guillen allegedly requested ₱10,000.00 for dinner expenses with CA Justice Lopez, which Khanna deposited. Miller Guillen later informed them that the CA justices expected half the amount, ₱6,000,000.00, after a 15-day period expired. Khanna's husband spoke with Judge Gomez-Guillen, who explained the justices' expectation. Khanna's group then ceased communication. Procedural History: Khanna filed an administrative complaint against the CA justices, Judge Exmundo, Judge Gomez-Guillen, and Sheriff Juan. The Supreme Court required the respondents to comment. Judge Exmundo denied the allegations, stating they were conjectures and that Atty. Hachuela was hired independently. He denied demanding money and claimed the text messages were part of the attorney-client relationship. Judge Gomez-Guillen admitted meeting Khanna but denied discussing the case or that she or her husband knew the CA justices. Sheriff Juan admitted the meeting but claimed Khanna offered him opportunities to earn commissions and denied knowing the CA justices, stating Khanna asked if they knew Justice Lopez and offered money. The respondent CA justices vehemently denied the allegations, stating they did not know Khanna or the other complainants and denied demanding money. They presented evidence of their whereabouts to prove they did not meet with Miller Guillen and NBI Paul. They maintained their resolution was based on law and jurisprudence. The Petition: Khanna sought an order directing Judge Exmundo and the CA justices to cease further proceedings and inhibit themselves from the cases.
Issue(s)
Whether there is substantial evidence to support the allegations of corruption and extortion against the respondent Associate Justices of the Court of Appeals. Whether the respondent Associate Justices of the Court of Appeals committed grave abuse of discretion in issuing the resolution granting the motion for execution pending appeal. Whether Judge Ronald H. Exmundo, Judge Fricia C. Gomez-Guillen, and Sheriff Apolinar S. Juan are administratively liable for corruption and extortion.
Ruling
The Supreme Court resolved to re-docket the administrative complaint against Judge Ronald H. Exmundo, Judge Fricia C. Gomez-Guillen, and Sheriff Apolinar S. Juan for further investigation. The administrative complaint against Associate Justices Edgardo L. Delos Santos, Marilyn B. Lagura-Yap, and Jhosep Y. Lopez of the Court of Appeals was dismissed for utter lack of merit.
Ratio Decidendi
On the allegations against the respondent Associate Justices of the Court of Appeals: The Court found no substantial evidence to support the allegations of corruption and extortion against the respondent Associate Justices of the CA. The complainant relied solely on hearsay evidence, specifically what Miller Guillen, Judge Gomez-Guillen, Sheriff Juan, or Paul from the NBI told her and/or her husband. The Court emphasized that in administrative proceedings, the burden of proof rests on the complainant, and hearsay evidence, without corroboration, has no probative value. The Court noted that the CA justices presented evidence of their whereabouts and that their assailed resolution was issued in the proper exercise of their judicial functions, based on existing law and jurisprudence, specifically Section 4, Rule 39 of the Rules of Court regarding judgments in actions for injunction. The Court also pointed out that the CA justices later issued a resolution granting Khanna's motion for reconsideration and staying execution upon posting of a bond, which indicated they were exercising their discretion and correcting their earlier resolution based on the merits, rendering the extortion allegations illogical. The presumption of good faith in the performance of official duties by judicial officers was upheld. On the alleged grave abuse of discretion by the respondent Associate Justices of the Court of Appeals: The Court ruled that the resolution issued by the respondent CA justices was a proper exercise of their judicial functions and was based on existing law and jurisprudence. The Court reiterated the principle that a judge may not be administratively sanctioned for mere errors of judgment in the absence of bad faith, fraud, malice, gross ignorance, corrupt purpose, or deliberate intent to do injustice. The resolution granting the motion for execution pending appeal was found to be supported by law and jurisprudence, particularly Section 4, Rule 39 of the Revised Rules of Court, which states that judgments in actions for injunction are not stayed by appeals. The Court found that the CA justices merely applied the law and that Khanna's dissatisfaction with the resolution was the reason for filing the administrative complaint, which was deemed an attempt to pressure and harass them. On the administrative liability of Judge Exmundo, Judge Gomez-Guillen, and Sheriff Juan: The Court found that the evidence presented by Khanna, based on her personal knowledge, if established, would be sufficient to hold Judge Exmundo, Judge Gomez-Guillen, and Sheriff Juan administratively liable. The Court noted that these officials and personnel of the court preyed on a willing victim, allowing themselves to be part of a scheme to thwart the administration of justice, which tarnished the image of the judiciary. Consequently, the administrative complaint against them was re-docketed as a regular administrative matter for further investigation by the Court Administrator.
Main Doctrine
Administrative complaints against judicial officers must be supported by substantial evidence. Hearsay evidence, without corroboration, is insufficient to establish administrative liability. Judicial officers acting in good faith within the scope of their official functions are not subject to administrative disciplinary action for mere errors of judgment.