G.R. No. CAJ-04-41; September 22, 2004
Antonio K. Litonjua, complainant, vs. Court of Appeals Justices Juan Q. Enriquez, Jr. and Bernardo P. Abesamis, respondents.

FACTS

The administrative complaint stemmed from consolidated petitions for prohibition (CA-G.R. SP Nos. 64419 and 64449) before the Court of Appeals’ Special Eleventh Division, involving American Realty Corporation (ARC). ARC had obtained a final Supreme Court judgment against Bank of America (BA). A faction of the Litonjua family (ARC-Eduardo) later entered into a compromise agreement with BA, while another faction (ARC-Aurelio/ Antonio) moved for execution in the RTC. To halt the execution, ARC (Eduardo) and BA filed petitions for prohibition with the CA. The division, where respondent Justice Juan Q. Enriquez, Jr. was a member, issued a Temporary Restraining Order and later a Preliminary Injunction against the execution, which was eventually dissolved but later reinstated via an Amended Decision.
Complainant Antonio K. Litonjua charged Justice Enriquez with serious misconduct for allegedly extorting ₱1.5 million to facilitate a resolution and with gross ignorance of the law for the proceedings in the CA cases. Justice Bernardo P. Abesamis was charged with serious misconduct for allegedly exerting undue influence over Justice Enriquez to secure the TRO and injunction.

ISSUE

Whether respondents Court of Appeals Justices Juan Q. Enriquez, Jr. and Bernardo P. Abesamis are administratively liable for serious misconduct and gross ignorance of the law.

RULING

The Supreme Court DISMISSED the administrative complaints for failure of the complainant to substantiate the charges with clear and convincing evidence. The Court emphasized that in administrative proceedings, the burden of proof lies with the complainant, and the standard of proof required is substantial evidence. Charges as grave as misconduct and gross ignorance of the law demand proof that is clear, convincing, and free from doubt.
The Court found the evidence against Justice Enriquez, particularly the extortion allegation, to be uncorroborated and insufficient. His judicial actions, including the issuance of the TRO, injunction, and the Amended Decision, were collegial acts of the division and fell within the exercise of judicial discretion, not amounting to gross ignorance. There was no evidence to show any manifestly unjust or erroneous application of law that would constitute gross ignorance. Regarding Justice Abesamis, the complainant failed to present any credible evidence to prove the allegation of exerting undue influence. The Court accorded great weight to the findings of the Investigating Justice, who evaluated the evidence as lacking in merit. The Court reiterated that while it does not condone any act diminishing public faith in the judiciary, it will also protect judicial officers from unfounded suits that disrupt the administration of justice.