Joven v. Quisumbing-Ignacio
REITERATIONFacts
The Antecedents: Complainant Maria Magdalena R. Joven (Joven) filed a Letter-Complaint against Judge Monique Quisumbing-Ignacio, Sheriff Victor Pe Benito, and Administrative Aide Alfredo Marcelo Bermejo of RTC, Mandaluyong City, for alleged gross ignorance of the law, gross misconduct, conduct prejudicial to the best interest of the service, and violations of the New Code of Judicial Conduct. The charges stemmed from Civil Case No. R-MND-18-00315-CV, a case for recovery of property filed by Anna Marie Sison against Joven. Procedural History: During the hearing on March 20, 2018, the respondent judge addressed Sison's motion for a Writ of Preliminary Mandatory Injunction and Joven's Omnibus Motion to Dismiss. Several orders were issued regarding the filing of pleadings and comments. Perion, Sison's attorney-in-fact, filed her opposition late, prompting Joven to file a Motion to Expunge. The pre-trial conference was scheduled for May 15, 2018, but only Perion's counsel appeared and submitted her pre-trial brief late and without furnishing Joven's counsel a copy. Joven's counsel moved for dismissal, but the judge referred the case to mediation and judicial dispute resolution, canceling the pre-trial. Subsequently, the judge issued orders denying Joven's motions to strike out and to dismiss, and granting Perion's formal offer of evidence. Joven alleged that the judge corrected Perion's errors. The judge denied Joven's motion to dismiss, stating the case should be decided on the merits, and reset the pre-trial. A separate order granted Perion's motion for a Writ of Injunction, conditioned on posting a bond. The Writ of Injunction was issued on June 7, 2018. Joven filed a motion for reconsideration and inhibition, alleging delayed receipt of orders. She also filed a motion to recall the writ and for inhibition, which was reset multiple times. The judge proceeded with the pre-trial on July 24, 2018, despite Joven's counsel appearing specially. An order dated August 10, 2018, directed Joven to show cause why she should not be cited for contempt for disobeying the writ. Joven explained her reasons, including the pendency of incidents and the non-implementation of the writ by Sheriff Pe Benito. Joven filed another motion for judicial dispute resolution and inhibition, citing Bermejo's relationship with Perion's counsel. On September 11, 2018, the case was referred to mediation. After mediation, Joven was arrested pursuant to a warrant of arrest issued by Judge Quisumbing-Ignacio for indirect contempt of court for refusing to comply with the Writ of Injunction. Her motion for bail was denied, stating she would remain imprisoned until compliance. Joven concluded that the respondents' acts violated R.A. 3019. The Petition: The Judicial Integrity Board (JIB) recommended the dismissal of the administrative complaint for lack of merit and for being judicial in nature. The Supreme Court adopted this recommendation.
Issue(s)
Whether the administrative complaint filed by Joven against Judge Quisumbing-Ignacio, Sheriff Pe Benito, and Bermejo is the proper remedy for the alleged irregularities in the Civil Case. Whether Judge Quisumbing-Ignacio acted with gross ignorance of the law, gross misconduct, or conduct prejudicial to the best interest of the service in issuing the assailed orders and processes in the Civil Case, including the issuance of the Writ of Injunction, Contempt order, and the handling of the Compromise Agreement. Whether Sheriff Pe Benito and Bermejo are liable for their actions in the Civil Case.
Ruling
The Supreme Court dismissed the administrative complaint for lack of merit and for being judicial in nature. The Court held that the alleged errors raised by Joven pertained to the exercise of judicial discretion and should have been addressed through appropriate judicial remedies, not an administrative complaint. Joven failed to substantiate her claims of bad faith, bias, and partiality with substantial evidence. The actions of Sheriff Pe Benito and Bermejo were also found to be without substantial evidence of misconduct.
Ratio Decidendi
On the propriety of the administrative complaint: The Court reiterated the principle that an administrative complaint is not the proper remedy for every judicial act deemed aberrant or irregular, especially when a judicial remedy exists. Citing Santos v. Orlino, Biado v. Hon. Brawner-Cualing, Bello III v. Judge Diaz, and Ala v. Judge Peras, the Court emphasized that the acts of a judge in their judicial capacity are not subject to disciplinary action unless performed in bad faith. The alleged errors in the Civil Case were acts of judicial discretion, and Joven's proper recourse was through judicial remedies, such as a petition for certiorari, which she had already filed but was dismissed for being out of time. This further bolstered the impropriety of the administrative complaint. On the alleged bias and bad faith of Judge Quisumbing-Ignacio, the issuance of the Writ of Injunction and Contempt, and the Compromise Agreement: The Court found that Joven failed to substantiate her claims that Judge Quisumbing-Ignacio acted in bad faith, with bias, and partiality. The standard of substantial evidence requires a reasonable ground to believe that the respondent is responsible for the misconduct, even if the evidence is not overwhelming. Joven's allegations were mere conjectures and speculations, lacking adequate proof. The Court clarified that bad faith implies a dishonest purpose or conscious doing of a wrong, not merely bad judgment or negligence. The adverse nature of the orders against Joven did not automatically imply bad faith or malice on the part of the judge. The judge's explanation regarding the timely receipt of orders by Perion's counsel and the mailing of orders to Joven, as well as the volume of cases, provided reasonable grounds for the court's actions. The Court noted that Joven's contention that the Writ of Injunction was issued prematurely and that her motions were denied without proper resolution was part of the judicial discretion exercised by the judge. The judge's decision to proceed with the pre-trial and eventually issue a warrant of arrest for contempt was based on Joven's alleged refusal to obey the court's directives, which the judge believed was a deliberate act to prevent her eviction. The judge's explanation for denying the motion for bail was also deemed legally sound. The Court took note of the subsequent development that Joven and Perion entered into a Compromise Agreement, which was approved by the RTC, and that Joven had already vacated the property. This indicated that the underlying dispute in the Civil Case had been resolved, further diminishing the relevance of the administrative complaint concerning the judge's actions. On the actions of Sheriff Pe Benito and Bermejo: Similar to the allegations against the judge, Joven failed to present substantial evidence to prove the misconduct of Sheriff Pe Benito and Bermejo. Sheriff Pe Benito's participation was limited to his ministerial duty of serving the writ of injunction and an order. Regarding Bermejo, Joven did not show how his relationship with Perion's counsel influenced the judge's issuances. Therefore, these claims were also dismissed for lack of merit.
Main Doctrine
An administrative complaint is not the proper remedy for every judicial act deemed aberrant or irregular, especially when a judicial remedy exists and is available. The acts of a judge in their judicial capacity are not subject to disciplinary action unless they act in bad faith, with malice, or with dishonest purpose.