G.R. No. A.M. No. 1328-MJ July 30, 1976
VIRGINIA DE GUZMAN, complainant, vs. JUDGE ROMEO C. DE LEON, respondent.

FACTS

Complainant Virginia de Guzman filed an administrative complaint for oppression and grave misconduct against respondent Municipal Judge Romeo C. de Leon of Antipolo, Rizal. The complaint stemmed from the judge’s issuance of a writ of preliminary mandatory injunction in a forcible entry case (Civil Case No. 817) filed against de Guzman and her husband by Marie G. Carlos. The writ resulted in the couple’s eviction and, allegedly, the demolition of their hut. De Guzman alleged the judge acted with bad faith, refusing to admit evidence that would have shown the forcible entry suit was a diversionary tactic to sidestep a pending government reversion case (Civil Case No. 18914) concerning land titles in Antipolo. She further complained the writ was issued on a Saturday, with demolition occurring the next day.
Respondent Judge denied the allegations. He asserted the writ was issued only after a full hearing with a 98-page transcript and several postponements, and he had no prior knowledge of the separate reversion case. He clarified the title in his case was not among those sought to be annulled by the government. The case was referred for investigation to Executive Judge Ramon V. Jabson, who recommended dismissal after finding no evidence of misconduct.

ISSUE

Whether respondent Judge Romeo C. de Leon is administratively liable for oppression and grave misconduct in issuing the writ of preliminary mandatory injunction.

RULING

The Supreme Court dismissed the complaint and exonerated respondent Judge. The legal logic rests on the principle that for an administrative complaint against a judge to succeed, there must be proof beyond reasonable doubt of partial, malicious, corrupt, arbitrary, or oppressive conduct, as established in In re Horrilleno. The investigation revealed no such proof. The evidence showed the judge conducted a proper hearing before issuing the writ. The claim that he refused to admit certain documents was unsubstantiated, as the transcripts contained no record of their formal offer, and the complainant’s counsel did not rectify the omission at the time. The judge could not rule on evidence not presented.
Furthermore, the writ only ordered vacation of the premises, not demolition. The sheriff’s return indicated voluntary compliance, and photographs showed the hut remained intact, contradicting the demolition claim. Any unauthorized demolition was the act of a private party, not sanctioned by the court. While the Court noted that judges should be circumspect with orders causing potential hardship, the respondent’s actions here were within judicial bounds and not tainted by bad faith. The complaint appeared motivated by deep-seated resentment from an adverse ruling, not by judicial misconduct.