Elgar v. Santos
REVERSALFacts
The Antecedents: Complainant Susan R. Elgar filed a verified Complaint-Affidavit against respondent Judge Soliman M. Santos, Jr. for gross ignorance of the law and violations of the Code of Judicial Conduct and Canons of Judicial Ethics. The alleged infractions stemmed from the respondent's handling of Special Proceedings No. 1870, a petition for the allowance of a deed of donation mortis causa. Procedural History: The Supreme Court, in a Decision dated February 4, 2020, found the respondent judge guilty of violation of Supreme Court rules, directives and circulars, Simple Misconduct, Gross Inefficiency or Undue Delay, and Gross Ignorance of the law, imposing fines totaling P78,000.00. The respondent judge filed a Motion for Partial Reconsideration seeking to reverse or reduce the findings of guilt and the imposed fines. The Petition: The respondent judge, in his Motion for Partial Reconsideration, prayed for the reversal of findings of guilt and fines for specific offenses, reduction of fines for others, operationalization of A.M. No. 03-10-01-SC against the complainant's counsel, removal of the Decision from the Supreme Court website pending resolution, and other just reliefs.
Issue(s)
Whether the Court should reconsider its Decision dated February 4, 2020, finding respondent Judge Soliman M. Santos, Jr. guilty of various administrative offenses and imposing fines totaling P78,000.00.
Ruling
The Supreme Court partly granted the respondent's Motion for Partial Reconsideration. The Court modified its Decision dated February 4, 2020, reducing the administrative liability for giving the oppositor the option of submitting a pre-trial brief from gross ignorance of the law to a violation of Supreme Court rules, directives, and circulars. The Court imposed a fine of P10,000.00 each for (1) violation of Supreme Court rules, directives and circulars (covering failure to refer to PMC and optional pre-trial brief submission) and (2) Simple Misconduct (covering undue castigation of counsel and pressing for settlement beyond propriety). The penalty for Simple Misconduct was understood to include the penalty for undue delay in terminating the preliminary conference. The total fine was reduced to P20,000.00. The respondent judge was sternly warned against repetition of similar acts.
Ratio Decidendi
On the Issue of Reconsideration: The Court partly granted the Motion for Partial Reconsideration. It maintained its finding that the respondent violated Supreme Court rules, directives, and circulars by failing to refer the case to the Philippine Mediation Center (PMC), as the case was mediatable. The Court also upheld the finding that the respondent exceeded the bounds of propriety in issuing an Extended Order that unduly castigated complainant's counsel, especially after the petition had been withdrawn. However, regarding the act of giving the oppositor the option to submit a pre-trial brief, the Court reconsidered its ruling. While acknowledging that making the submission optional was improper, the Court found that the respondent's prior orders and reprimands indicated awareness of the mandatory nature of pre-trial briefs. Thus, this act was reclassified from gross ignorance of the law to a violation of Supreme Court rules, directives, and circulars. The Court also found that the respondent's actions, while improper, were not attended by bad faith or malice, but rather by a genuine intention to facilitate amicable settlements. This absence of bad faith was considered a mitigating circumstance in imposing penalties. The Court determined that a fine of P10,000.00 each for the violations of Supreme Court rules, directives, and circulars, and for Simple Misconduct, totaling P20,000.00, would be sufficient. The penalty for Simple Misconduct was deemed to encompass the undue delay in terminating the preliminary conference.
Main Doctrine
The Supreme Court, in resolving a motion for partial reconsideration, modified its earlier decision finding a judge guilty of several administrative offenses. While upholding some findings of guilt, the Court reduced the classification of one offense from gross ignorance of the law to a violation of Supreme Court rules, directives, and circulars, and consequently adjusted the total fines imposed. The Court emphasized that while good faith does not absolve a judge from liability, the absence of malice and corrupt motives can be mitigating factors in determining the penalty. The Court also clarified that A.M. No. 03-10-01-SC is not applicable to complaints found to be meritorious, and that decisions are posted on the website upon promulgation, not after the resolution of a motion for reconsideration.