Baysa v. Santos
REITERATIONFacts
The Antecedents: Respondent Marietta Santos (Santos) filed a complaint before the Office of the Ombudsman (OMB) against petitioner Andrew N. Baysa (Baysa), a Provincial Adjudicator of the DARAB, for unjust judgment and erroneous issuance of a Writ of Demolition. Santos alleged that Baysa rendered a decision in a DARAB case involving tenants and Spouses Pascual, which became final and executory. Subsequently, a writ of execution and a motion for demolition were issued. Although Santos was not a party to the original case, she was furnished copies of pleadings and later, a writ of demolition was attempted to be served on her. She discovered that her building was on a portion of her property sought to be demolished. She filed for injunctive relief and a motion before the DARAB to subject the sheriff to disciplinary action and to desist from disturbing her property rights, asserting lack of jurisdiction over her person. Baysa denied her motion, stating that her title was derived from Spouses Pascual, thus she was bound by the decision. He also asserted she was afforded due process as she participated in the execution proceedings. Procedural History: The OMB found Baysa guilty of Simple Misconduct and suspended him for three months without pay, citing his disregard of laws and jurisprudence in ordering the demolition of Santos' property without due process. The Court of Appeals affirmed this decision, holding that Baysa erred in considering Santos a successor-in-interest and that the writ of demolition violated her right to due process because she was not impleaded, not afforded an opportunity to be heard, and her property was distinct from the subject of the DARAB case. The Court of Appeals denied reconsideration. The Petition: Baysa filed a petition for review on certiorari with the Supreme Court, arguing that Santos was not deprived of due process, his orders had factual and legal bases, he did not exceed the scope of his decision, and Santos' caretaker received the writ of execution on her behalf. The Office of the Solicitor General adopted its arguments from the Court of Appeals.
Issue(s)
Whether petitioner Baysa committed simple misconduct in ordering the demolition of Santos' property without due process. Whether disciplinary proceedings are a substitute for judicial remedies for errors of judgment by an officer exercising quasi-judicial functions.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision and resolution of the Court of Appeals, and dismissed the complaint against petitioner Andrew N. Baysa for misconduct. ACCORDINGLY, the petition is GRANTED. The Decision dated January 14, 2020 and Resolution dated October 26, 2020 of the Court of Appeals in CA-G.R. SP No. 149699 are REVERSED and SET ASIDE. The complaint against petitioner ANDREW N. BAYSA for misconduct is DISMISSED.
Ratio Decidendi
On the issue of whether petitioner Baysa committed simple misconduct: The Court held that disciplinary proceedings against officers exercising quasi-judicial powers are not a substitute for judicial remedies. Petitioner Baysa's alleged infraction pertained to the exercise of his quasi-judicial functions. Errors in judgment by such an officer may be corrected through available judicial remedies, such as appeals to the DARAB, petitions for review to the Court of Appeals, or petitions for certiorari. The Court noted that Santos had previously filed a petition for certiorari before the Court of Appeals where it was found that Baysa committed grave abuse of discretion in ordering the demolition of her building without her being a party to the case. However, the Court emphasized that for administrative liability, there must be a clear showing of bad faith, malice, or intentional wrongdoing. The Court found no evidence that Baysa's dispositions were motivated by a premeditated, obstinate, or intentional purpose, nor that he acted in bad faith or malice. The Court pointed out that Santos herself characterized Baysa's actions as mere errors in judgment ("maling hatol" and "maling akala"). Furthermore, Baysa did afford Santos an opportunity to be heard by entertaining her motions and allowing her to present evidence, even if he ultimately ruled against her. This opportunity to be heard militates against a finding of bad faith. Therefore, Baysa could not be held liable for misconduct. On the issue of whether disciplinary proceedings are a substitute for judicial remedies: The Court reiterated the principle that disciplinary proceedings are not complementary or suppletory to, nor a substitute for, judicial remedies. Resort to and exhaustion of judicial remedies are prerequisites for inquiring into an officer's administrative liability. The Court cited Flores v. Abesamis and Atty. Tamondong v. Judge Pasal to support the proposition that acts of an officer in their judicial capacity, no matter how erroneous, cannot be corrected through administrative proceedings if a judicial remedy exists and is available, provided the officer acts in good faith. The Court stressed that an administrative complaint is not the appropriate remedy for every aberrant or irregular act where a judicial remedy is available. The Court found that Baysa's alleged errors in judgment could and should have been addressed through the proper judicial channels, and the administrative complaint was not the proper venue absent a showing of bad faith.
Main Doctrine
Disciplinary proceedings against government officers exercising quasi-judicial powers are not a substitute for judicial remedies. Errors in judgment, absent bad faith, malice, or intentional wrongdoing, do not constitute administrative offenses like misconduct.