GR L 57821; (January, 1985) (Digest)
March 15, 2026GR 31115; (February, 1978) (Digest)
March 15, 2026G.R. No. A.M. No. 1037-CJ October 28, 1981
MARTIN LANTACO, SR., ESTEBAN DEL BARRIO, ROSALITO ALAMAG and BORROMEO VITALIANO, complainants, vs. CITY JUDGE FRANCISCO R. LLAMAS, respondent.
FACTS
Complainants, jeepney drivers and the complaining witnesses in four estafa cases, filed an administrative complaint against City Judge Francisco R. Llamas for “Backsliding and Grave Abuse of Discretion.” The cases involved the non-remittance of SSS premiums. After trial, respondent judge acquitted the accused. Following the promulgation, complainants repeatedly requested a copy of the decision. Respondent initially instructed a stenographer to prepare a copy but later caused delays. The stenographer eventually informed them the case folder was at the judge’s house for “correction,” raising suspicions about post-promulgation alterations.
Respondent ignored several directives from the Supreme Court to comment on the complaint. He finally submitted a brief comment, asserting the validity of the acquittal and claiming copies were furnished to the prosecution and defense. He attached the decision as an annex but did not specifically address or deny the allegations regarding the undue delay and refusal to provide complainants a copy.
ISSUE
Whether respondent judge is administratively liable for his actions concerning the complainants’ request for a copy of the decision and for the alleged errors in his judgment of acquittal.
RULING
Yes, but only for his conduct in denying access to the decision, not for the acquittal itself. The Supreme Court found respondent guilty of grave abuse of authority for unjustly refusing to furnish the complainants a copy of the promulgated decision. The decision was a public record, and the complainants, as interested parties, had a constitutional right to information on matters of public concern. Respondent’s actions—giving the complainants the “run-around,” denying a xerox copy, and causing unexplained delays—were oppressive and arbitrary. This violated the people’s right to access official records as recognized under the Constitution.
However, the Court exonerated respondent from liability for his judgment acquitting the accused. An error of judgment, absent proof of bad faith, corruption, or a persistent disregard of well-known rules, does not constitute administrative misconduct. Judges cannot be held administratively accountable for every erroneous ruling, as this would make their position untenable. The legal logic distinguishes between administrative accountability for procedural misconduct (like denying access to records) and immunity for judicial discretion exercised in good faith, even if mistaken.
For his grave abuse of authority and disrespect to the Court by ignoring its directives, respondent was suspended from office for three (3) months without pay. Justices Barredo, De Castro, and Batas Pambansa concurred with this penalty, emphasizing that the refusal to provide the copy was the actionable wrong, not the substantive decision.
