A.M. No. CA-90-11 October 18, 1990
PILIPINAS BANK, complainant, vs. JUSTICE SOCORRO TIRONA-LIWAG, respondent.

FACTS

Pilipinas Bank filed an administrative complaint against then Judge Socorro Tirona-Liwag for gross ignorance of the law, partiality, and knowingly rendering unjust orders in Civil Case No. 5260. The case originated from a complaint for damages with injunction filed by Rustica Tan to stop the bank’s extrajudicial foreclosure. After the bank’s motion to dismiss was denied, it failed to file a timely answer. The original presiding judge, Judge Zoilo Aguinaldo, declared the bank in default on October 14, 1985, and allowed the plaintiffs to present evidence ex-parte. The plaintiffs subsequently presented evidence claiming damages totaling over P11 million, exceeding the amount originally prayed for in their complaint.
Judge Aguinaldo later set aside the default order on October 21, 1986, admitted the bank’s answer, and allowed cross-examination of the plaintiff, but ordered that the evidence already presented “shall remain as part of the record.” The case was then transferred to respondent Judge Liwag. On August 24, 1987, Judge Liwag ordered the bank’s counsel to furnish the plaintiffs’ counsel a copy of its answer. When the bank’s counsel failed to comply and failed to appear at a hearing, Judge Liwag, in an order dated November 9, 1987, granted the plaintiffs’ motion to strike out the answer, declared the bank in default for a second time, and allowed the presentation of the last witness ex-parte. This led to a judgment based on the previously adduced evidence, awarding damages greater than those initially sought.

ISSUE

Whether respondent Judge Socorro Tirona-Liwag is administratively liable for gross ignorance of the law or misconduct for issuing the second order of default and rendering a judgment based on evidence presented during the first default period.

RULING

The Court dismissed the administrative complaint and absolved Judge Liwag of any liability. The ruling clarified that the second order of default issued by Judge Liwag had a legal basis because the bank failed to serve a copy of its answer upon the adverse party as expressly directed by the court, a procedural requirement established in jurisprudence. The award of damages, though exceeding the amount in the original prayer, was based on evidence that had been formally presented and explicitly allowed to remain on record by the prior judge’s order, which the bank did not object to at the time.
The Court emphasized that a judge cannot be held administratively liable for errors of judgment committed in good faith. The peculiar circumstances showed that Judge Liwag’s actions, including the so-called “unusual” default judgment, were rooted in the bank’s procedural lapses and the existing evidentiary record. The settled doctrine is that a judge incurs no civil, criminal, or administrative liability for an erroneous decision or order rendered in good faith, absent any showing of malice, fraud, or corruption. The complaint merely highlighted an arguable error in judicial discretion, not a transgression warranting administrative sanction.