AM CA 04 39; (October, 2004) (Digest)
G.R. No. A.M. No. CA-04-39; October 5, 2004
Dante P. Flores, complainant, vs. Justice Bennie A. Adefuin-de la Cruz, Justice Wenceslao I. Agnir, Jr., Justice Rebecca De Guia-Salvador, and Division Clerk of Court Josefina C. Mallari, Court of Appeals, respondents.
FACTS
The administrative complaint originated from a letter filed by Dante P. Flores, a union member, against several Court of Appeals justices and a clerk of court. The complaint alleged grave abuse of discretion, ignorance of the law, and violation of the lawyer’s oath in relation to a CA decision dated December 21, 2001. That decision nullified a 1993 National Labor Relations Commission (NLRC) ruling which had ordered the reinstatement of dismissed Philippine Veterans Bank employees, thereby effectively reinstating an earlier Labor Arbiter’s decision dismissing the union’s claims for lack of merit. The complainant contended the CA erroneously entertained the bank’s petition despite the NLRC decision being final and executory, and criticized the CA’s legal interpretation regarding a compromise agreement and the propriety of a certiorari petition.
ISSUE
Whether the respondent justices and court official are administratively liable for gross ignorance of the law or grave abuse of discretion in rendering the assailed decision.
RULING
The Supreme Court dismissed the administrative complaint for lack of merit. The Court emphasized that an administrative complaint is not the proper remedy to assail a judicial decision. The allegations pertained solely to the respondents’ appreciation of evidence and their interpretation and application of laws and jurisprudence, which are matters falling within the exercise of judicial discretion and are correctible only through judicial review or appeal, not through an administrative case. The Court reiterated the doctrine from In Re: Joaquin T. Borromeo that administrative or criminal actions cannot serve as substitutes for appeal. As long as a judge acts in good faith and without malice, errors in judgment, assuming any existed, do not warrant administrative sanction. The charge of grave abuse of discretion likewise fails, as such a writ pertains to jurisdictional errors, not to mere errors of judgment which are reviewable by higher courts. Furthermore, the complaint against Justice Agnir was moot as he had already compulsorily retired, and the Court found no basis in the records to hold any respondent administratively liable.