AC 279 J; (May, 1974) (Digest)
G.R. No. A.C. No. 279-J. May 30, 1974.
Gregoria V. Bondoc, complainant, vs. Hon. Jose de Guzman, respondent.
FACTS
Complainant Gregoria V. Bondoc, mother of the alleged victim, charged respondent Judge Jose de Guzman with gross ignorance of the law, grave abuse of discretion, and knowingly rendering an unjust judgment. The judge had acquitted the accused, Florante Bungay, in two consolidated rape cases but ordered him to pay civil indemnity to the victim and her parents. The complainant’s allegations included that the prosecution presented more witnesses than the defense, that the accused had asked for forgiveness, implying guilt, that the decision lacked factual findings, and that the decision was allegedly known to the accused’s family before its official promulgation.
ISSUE
Whether the respondent judge’s decision acquitting the accused but awarding civil damages, and his conduct during the proceedings, constitute grounds for administrative discipline based on gross ignorance of the law or rendering an unjust judgment.
RULING
The Supreme Court dismissed the complaint, finding no basis for administrative liability. The Court clarified it was not reviewing the correctness of the acquittal but assessing whether the judge’s actions indicated bad faith, fraud, or gross ignorance. On the number of witnesses, the Court upheld the judge’s application of the settled legal principle that witnesses are to be weighed, not numbered. A conviction must rest on the strength of the prosecution’s evidence proving guilt beyond reasonable doubt, not on the defense’s weakness or the mere quantity of witnesses.
Regarding the alleged forgiveness sought by the accused, the respondent judge correctly noted these incidents were not part of the official record, as they occurred outside court sessions without his presence or knowledge. A judge cannot be held administratively liable for events not presented as evidence. The claim of premature knowledge of the decision was refuted by sworn statements from court personnel and deemed baseless. Finally, the award of civil liability under Article 21 of the Civil Code, despite acquittal based on reasonable doubt, was not devoid of legal basis given the circumstances and the moral injury involved. The judge’s detailed decision demonstrated a reasoned evaluation of evidence, not arbitrariness. Absent proof of malicious intent or gross judicial error, the complaint lacked merit.