AM RTJ 05 1896; (April, 2005) (Digest)
A.M. No. RTJ-05-1896. April 29, 2005. ATTY. JULIUS NERI, Complainant, vs. JUDGE JESUS S. DE LA PEÑA, Respondent.
FACTS
This administrative case for grave misconduct and gross ignorance of the law arose from Civil Case No. CEB-16474, where Emmanuel Aznar sued Citibank for damages after his credit card was allegedly dishonored abroad. The trial court (Branch XX) dismissed the case. Upon Aznar’s motion for reconsideration, the acting presiding judge ordered the case re-raffled, citing his heavy workload and the original judge’s status as a Citibank cardholder. The case was re-raffled to respondent Judge Jesus S. de la Peña’s branch.
Respondent judge granted Aznar’s motion for reconsideration, reversing the dismissal and awarding him ₱16.2 million in damages. Complainant Atty. Julius Neri, Citibank’s counsel, charged respondent with dishonesty for rendering the decision without reading the case transcripts, as certified by the clerks of court. He also alleged gross ignorance for improperly admitting a computer print-out as a business record despite lack of foundation, ignoring Citibank’s evidence, and awarding scandalously excessive damages.
ISSUE
Whether respondent Judge Jesus S. de la Peña is administratively liable for his actions in rendering the assailed order.
RULING
Yes, respondent is administratively liable. The Supreme Court found him guilty of knowingly rendering an unjust judgment or order. The legal logic is anchored on the violation of fundamental judicial norms. First, respondent based his reversal primarily on an ex parte manifestation filed by Aznar’s counsel, which was defective for lack of service to the adverse party and for being filed after office hours. Reliance on such a defective document constitutes gross impropriety and violates the duty to avoid even the appearance of impropriety under the Code of Judicial Conduct.
Second, the Court of Appeals subsequently vacated respondent’s order and reinstated the original dismissal, confirming its erroneous nature. While an erroneous judgment is not per se administratively culpable, the highly anomalous circumstances here—failing to verify the transcripts, improperly admitting evidence, and awarding patently exorbitant damages—transcend mere error and indicate a conscious disregard of basic procedural and substantive rules. This constitutes a breach of the standard that a judge’s judgment must be just and rendered with conscientiousness. The Court imposed a six-month suspension, with a warning that a repetition would merit a harsher penalty.