G.R. No. A.M. No. R-710-RTJ May 21, 1993
FILOMENO R. NEGADO, complainant, vs. JUDGE MANUEL E. AUTAJAY, RTC, Carigara, Leyte (Branch 13), respondent.

FACTS

Complainant Filomeno R. Negado, a practicing lawyer, filed an administrative complaint on July 10, 1986, against respondent Judge Manuel E. Autajay, then Presiding Judge of the RTC of Carigara, Leyte (Branch 13). The respondent Judge had since retired, and his retirement benefits were partially withheld pending the resolution of this and another administrative case. The charges against Judge Autajay included corrupt practices, impropriety, abuse of discretion, dishonesty, lack of integrity, incompetence, ignorance of the law, and favoritism. The case was referred to Justice Jesus M. Elbinias of the Court of Appeals for investigation. The evidence presented by the complainant consisted of affidavits and documents from certain court cases. Specifically, an affidavit from Antonio Oledan alleged that a caretaker named “Junior” delivered fish and seafood to the Judge’s house as gifts. An affidavit from Materno Torredes claimed the Judge attended social affairs of litigants and showed favoritism to certain lawyers. Documents from four civil cases and an affidavit from Raquel Pamanian in a murder case were submitted to support charges of abuse of discretion, incompetence, and ignorance of the law.

ISSUE

Whether the evidence presented by the complainant is sufficient to prove the administrative charges of corrupt practices, impropriety, abuse of discretion, dishonesty, lack of integrity, incompetence, ignorance of the law, and favoritism against respondent Judge Manuel E. Autajay.

RULING

The Supreme Court DISMISSED the complaint and ordered the immediate payment of the withheld retirement benefits to respondent Judge. The Court agreed with the findings of the Investigating Justice that the evidence was insufficient. The affidavit of Antonio Oledan was deemed hearsay, as the alleged deliverer “Junior” was not presented to testify. The affidavit of Materno Torredes contained mere conclusions and hearsay without specific details. Regarding the charges based on judicial actions in specific cases, the Court held that any alleged errors were judicial in nature, correctable through appellate processes, and not a proper basis for administrative sanction absent proof of gross ignorance, bad faith, or a knowingly unjust decision. The Court cited precedents stating that not every erroneous ruling warrants administrative accountability, and mere errors in appreciation of evidence are irrelevant in administrative proceedings unless they indicate gross ignorance or bad faith. A thorough review of the record revealed no adequate evidentiary foundation for any of the charges.