G.R. No. A.M. No. 156-J June 10, 1971
BIENVENIDO P. JABAN, complainant, vs. HON. SERAFIN R. CUEVAS, respondent.

FACTS

Complainant Atty. Bienvenido P. Jaban filed an administrative complaint against respondent Judge Serafin R. Cuevas of the CFI of Manila, Branch IV. The charge stemmed from the judge’s handling of Special Proceedings No. 25876, the Testate Estate of Amadeo Matute. Jaban had a final judgment for attorney’s fees against two heirs, Ramon and Trinidad Matute, which was enforceable against their hereditary shares. Prior judges in the estate proceedings had issued orders approving the payment and threatening the administrator with contempt for non-payment. Respondent Judge Cuevas, however, issued subsequent orders that allegedly frustrated Jaban’s efforts to collect his claim, which had been reduced to P600. The complaint accused the judge of negligence, inefficiency, undue delay in resolving motions, and of obstructing the execution of a final judgment from another court, thereby undermining the administration of justice.
After the Court required an answer, Jaban filed a “Withdrawal of Complaint,” stating he had already received satisfaction of his claim. He expressed a reconsidered belief that the respondent judge may have acted in good faith, possibly under an honest mistake, considering the complexity of the voluminous estate records and subsequent developments. Despite this withdrawal, the Court proceeded to resolve the administrative matter on its merits based on the pleadings already submitted, including the judge’s detailed explanation and the complainant’s allegations.

ISSUE

Whether the acts of respondent Judge Serafin R. Cuevas, as alleged in the complaint, constitute administrative culpability warranting disciplinary action.

RULING

The Court dismissed the administrative complaint. The core legal principle applied is that an error of judgment, absent proof of bad faith, fraud, dishonesty, or corruption, is not a ground for administrative sanction. The remedy for a party aggrieved by a judge’s order or decision is judicial, not administrative—specifically, an appeal or the appropriate appellate review to correct such error. The Court found that the complainant’s allegations, even if true, pertained to the respondent judge’s judicial actions and discretionary rulings in the estate proceedings. At most, these actions could amount to an error in the exercise of his adjudicatory functions.
The respondent judge, in his answer, provided a detailed justification for his orders, explaining the legal and procedural context of the estate case. Furthermore, the Court noted the complainant’s own withdrawal and retraction, wherein he conceded the possibility of an honest mistake and good faith on the part of the judge. The Court also acknowledged the respondent’s demonstrated record of productivity and a low reversal rate on appeal, indicating general competence. Since the charges did not establish any malicious intent, gross ignorance of the law, or conduct indicative of unfitness for office, but rather challenged judicial discretion, the administrative complaint was without merit. The proper recourse for the complainant was to seek correction of the alleged erroneous orders through the appellate process.