A.M. No. 252-J. April 30, 1976.
Hadji Esmayaten Lucman, complainant, vs. Hon. Agapito Hontanosas, respondent.

FACTS

Complainant Hadji Esmayaten Lucman, an assignee of a credit, was sued by Ben Uy Rodriguez in the Court of First Instance of Cebu, Branch XI, presided by respondent Judge Agapito Hontanosas (Civil Case No. R-12069). The administrative complaint alleged that Judge Hontanosas committed gross ignorance of the law, knowingly rendered unjust orders, and engaged in oppression. Specific acts cited included declaring Lucman in default for allegedly filing an answer out of time, rendering a separate ex parte decision against Lucman while a co-defendant had answered and was not in default, issuing orders for pre-trial without proper notice, and giving only ten days to amend a voluminous record on appeal.
A critical allegation involved a related criminal case for falsification (Criminal Case No. CU-356) also before Judge Hontanosas. Lucman claimed the judge, in his chambers on multiple occasions, pressured him to settle the civil case by delivering a check for P450,553.00 to Rodriguez, threatening to convict him in the criminal case if he refused.

ISSUE

Whether the acts of respondent Judge Hontanosas constitute gross ignorance of the law, knowingly rendering unjust decisions/orders, and oppression warranting administrative sanction.

RULING

The Supreme Court dismissed the charges and exonerated Judge Hontanosas. The Court, adopting the findings of the investigating Justice, held that the totality of the evidence failed to substantiate the accusations. On the charge of gross ignorance of the law, the Court found that while some procedural rulings (like the declaration of default and the separate judgment) might have been erroneous, they did not amount to gross ignorance absent proof of bad faith, malice, or corrupt motive. Judicial errors, correctible by appeal, are not necessarily administrative offenses.
Regarding the alleged oppression in the criminal case, the Court found the charge unsubstantiated. It acknowledged that while the prosecution of public offenses cannot be subject to amicable settlement, the respondent judge was merely exploring settlement possibilities given that the criminal and civil cases were factually intertwined. The judge flatly denied making any threats of conviction, and the complainant’s evidence was deemed insufficient to prove the serious allegation of judicial extortion. The remaining charges, such as the short period to amend the record on appeal and the alleged irregularity in setting the pre-trial, were considered minor, insubstantial, or unsupported by evidence. The Court concluded that the complainant failed to discharge the burden of proving, by substantial evidence, that the respondent acted with fraud, dishonesty, or corruption. Mere inaccuracies or errors in judgment, absent a showing of bad faith, do not constitute grounds for administrative liability.