G.R. No. A.M. No. MTJ-92-643 November 27, 1992
LOUIS VUITTON S.A., complainant, vs. JUDGE FRANCISCO DIAZ VILLANUEVA, presiding Judge, Branch 36, The Metropolitan Trial Court at Quezon City, Metro Manila, respondent.

FACTS

Complainant Louis Vuitton S.A. filed a complaint against Judge Francisco Diaz Villanueva for knowingly rendering a manifestly unjust judgment in Criminal Case No. XXXVI-62431, “People of the Philippines vs. Jose V. Rosario,” where Rosario was accused of unfair competition under Article 189 of the Revised Penal Code for selling goods bearing the “LOUIS VUITTON” and “LV” trademarks. Before judgment, the prosecution filed a “Prosecution’s Memorandum with Motion” praying for conviction or, alternatively, that the accused be committed to answer for the proper offense of “giving other persons a chance or opportunity to commit unfair competition” under Rule 119 of the 1985 Rules on Criminal Procedure. The trial court acquitted Rosario, finding that the prosecution failed to prove he was the manufacturer or seller of the seized articles, noting he signed an NBI inventory as “owner/representative” but was actually a stockholder and executive vice-president of the corporate entity Manila COD Department Store. The court also found the elements of unfair competition absent, as the seized goods (priced around P147) were of low quality and rough appearance compared to genuine Louis Vuitton products (costing P4,000-P5,000), and thus unlikely to deceive an ordinary purchaser. The complainant alleged the judge: (1) failed to resolve the prosecution’s alternative motion, violating his ministerial duty under Rule 119, Section 11; (2) ignored jurisprudence on unfair competition; (3) failed to consider the defense witness’s lack of credibility; and (4) delayed the promulgation of the decision beyond the constitutional three-month period. In his comment, the respondent judge argued the prosecution’s evidence was insufficient, the motion was not properly brought to his attention, and the private prosecutor’s memorandum indicated no mistake in charging the offense.

ISSUE

Whether respondent Judge Francisco Diaz Villanueva is administratively liable for knowingly rendering a manifestly unjust judgment, gross ignorance of the law, and undue delay in promulgation.

RULING

The complaint is DISMISSED for lack of merit. However, respondent judge is REPRIMANDED for the delay in promulgation. The Court held:
1. The respondent judge is not liable for knowingly rendering an unjust judgment. An unjust judgment implies a conscious and intentional wrongdoing. The judge’s findings were based on his assessment of the evidence, including the corporate personality of the store, the lack of proof linking the accused to the manufacture/sale of the goods, and the obvious difference in quality and price between the seized items and genuine products. His conclusion that the elements of unfair competition were not proven does not constitute gross ignorance of the law or bad faith. Judges cannot be held administratively accountable for every erroneous judgment, provided they acted in good faith.
2. The respondent judge is not liable for gross ignorance of the law regarding the prosecution’s alternative motion under Rule 119, Section 11. The provision requires the mistake to be “manifest at any time before judgment.” The prosecution’s own memorandum asserted it had “fairly proven” the accused’s guilt for the offense charged, which did not manifest a mistake. The alternative prayer was conditional and buried within a memorandum. The judge’s inaction on it, while perhaps an oversight, did not amount to gross ignorance.
3. The respondent judge is not liable for failing to assess the defense witness’s credibility, as this falls within his discretion in evaluating evidence.
4. The respondent judge is administratively liable for undue delay. The decision was dated June 28, 1991, but promulgated on October 25, 1991, violating the constitutional mandate to decide cases within three months. This warrants a reprimand.