A.C. No. 216-CFI September 30, 1975
Nonato Barroso, complainant, vs. District Judge Andres P. Arche, CFI, Branch II, Borongan, Eastern Samar, respondent.

FACTS

Complainant Nonato Barroso, a retired court stenographer, filed an administrative complaint against respondent Judge Andres P. Arche. The complaint stemmed from the judge’s adverse decision in Civil Case No. 1496, wherein Barroso sued the Government Service Insurance System (GSIS) for allegedly underpaying his retirement benefits. The judge dismissed Barroso’s claim for P38,874.00, upholding the GSIS’s standard computation which resulted in a payment of P22,590.00. Dissatisfied, Barroso charged the judge with dishonesty, oppression, incompetence, and inefficiency.
The case was referred to Justice Sixto Domondon of the Court of Appeals for investigation. Justice Domondon found that the administrative charges were directly intertwined with the errors Barroso assigned in his pending appeal (CA-G.R. No. 50346-R) from the same adverse decision. The investigator noted no significant evidence of bias or malice on the part of the judge, and found that the decision appeared to be based on a thorough appreciation of evidence. A charge of neglect of duty for alleged delay in deciding the case was also found to be without factual basis.

ISSUE

Whether respondent Judge Andres P. Arche may be held administratively liable based on the complainant’s dissatisfaction with the judge’s adverse decision in a civil case, which decision is pending appeal.

RULING

The Supreme Court dismissed the administrative complaint for lack of merit. The Court ruled the complaint was premature and improper. The issues raised administratively—essentially alleging judicial error—were the very same errors assigned in the pending appeal before the Court of Appeals. The Court emphasized that a losing litigant’s proper recourse is to seek correction of alleged errors through the appellate process, not by filing an administrative complaint. To hold a judge administratively accountable for every alleged erroneous ruling, especially while an appeal is sub judice, would constitute harassment and render the judicial position untenable.
The Court adopted the investigator’s finding that no evidence of malice, oppression, or wrongful conduct attended the rendition of the decision. Even if the appellate court eventually reverses the decision on appeal, such reversal, by itself, does not establish administrative liability absent a showing of bad faith, fraud, dishonesty, or corruption. The respondent judge was merely upholding the interpretation of the government agency tasked with implementing the retirement laws. The administrative complaint, filed while the appeal was pending, was therefore dismissed.