A.M. No. 1393-CTJ. January 20, 1977.
Rodrigo Cortez, complainant, vs. City Judge Avelino Constantino, Branch XII, Manila, respondent.

FACTS

Complainant Rodrigo Cortez filed an administrative complaint for grave abuse of discretion against respondent City Judge Avelino Constantino. The complaint stemmed from the judge’s decision acquitting Cerilo Regala in a criminal case for slight physical injuries. Cortez, the aggrieved party, alleged that the acquittal constituted such abuse. The case originated from a fistfight inside a jeepney, where Cortez claimed he was assaulted by Regala and two bystanders without provocation while he was alighting.
In an eleven-page decision, respondent Judge meticulously evaluated the evidence. He found the testimony of the accused Regala more credible. The judge highlighted inconsistencies in Cortez’s account, particularly regarding his level of intoxication. The medical certificate indicated Cortez had alcoholic breath, contradicting his claim of only a “small sip.” The judge reasoned that a five-minute drink would not cause such a finding hours later, concluding Cortez was in an inebriated state that affected his balance and reflexes. The court disbelieved the claim of mauling by bystanders, noting the crime report and information did not mention accomplices, and it was unlikely bystanders would join a fight in heavy rain. The judge concluded the fight likely started when Cortez, angered after slipping while alighting, threw the first punch, and Regala merely retaliated in self-defense.

ISSUE

Whether respondent City Judge Avelino Constantino committed grave abuse of discretion warranting administrative liability by acquitting the accused in the criminal case for slight physical injuries.

RULING

The Supreme Court dismissed the administrative complaint. The Court held that the judge’s detailed decision demonstrated a careful and conscientious evaluation of the evidence, focusing on the credibility of witnesses and the logical inferences from the facts. An acquittal based on a reasoned assessment of proof, where the prosecution fails to establish guilt beyond reasonable doubt, does not constitute abuse of discretion, much less a grave one warranting administrative sanction. The Court cited the doctrine in In re Horilleno, which states that liability attaches only for corrupt conduct, intentional violation of the law, or a persistent disregard of well-known legal rules. The respondent judge’s act was a legitimate exercise of judicial discretion in weighing evidence. There was no showing that the judgment was rendered maliciously, with inexcusable negligence, or in ignorance of the law. Therefore, an judge cannot be held administratively liable merely because a party disagrees with the factual findings and conclusion reached in a decision, provided it is grounded on the evidence presented.