A.M. No. MTJ-02-1404. December 14, 2004. EXEC. JUDGE HENRY B. BASILLA, complainant, vs. JUDGE AMADO L. BECAMON, Clerk of Court LOLITA DELOS REYES and Junior Process Server EDDIE DELOS REYES, MCTC, Placer-Esperanza-Cawayan, Masbate, respondents.
FACTS

Executive Judge Henry B. Basilla filed this administrative complaint against respondents Judge Amado L. Becamon, Clerk of Court Lolita delos Reyes, and Process Server Eddie delos Reyes. The charges—gross neglect of duty, grave misconduct, gross ignorance of the law, and violation of the Code of Judicial Conduct—stemmed from their handling of Civil Case No. 288 for recovery of possession. Specifically, complainant alleged that respondents delayed the release of the decision and an order denying reconsideration by one-and-a-half months and five months, respectively; improperly extended the period to appeal; and still accepted the appeal fee and approved the appeal long after the reglementary period had lapsed. These allegations were detailed in Judge Basilla’s Order dated April 5, 2000, which dismissed the appeal in the civil case and directed respondents to explain their actions.
However, an earlier administrative case, A.M. No. MTJ-02-1438, involving the same parties and arising from the very same factual circumstances and the identical April 5, 2000 Order, had already been filed and resolved by the Supreme Court. In a Resolution dated January 22, 2004, the Court found Judge Becamon liable for gross ignorance of the law and imposed a fine, while the co-respondents were found guilty of simple neglect of duty and were also fined. The present complaint, though filed separately, is a verbatim replication of the charges and issues already adjudicated in that prior case.

ISSUE

Whether the present administrative complaint against the respondents should be dismissed on the ground of res judicata, it being a mere duplication of a prior administrative case already resolved by the Supreme Court.

RULING

Yes, the complaint is dismissed. The principle of res judicata applies to administrative cases. For res judicata to bar a subsequent action, the following must concur: (1) a final former judgment; (2) a court of competent jurisdiction rendered the judgment; (3) the judgment is on the merits; and (4) there is identity of parties, subject matter, and causes of action between the first and second actions. All these elements are present here. The Court’s en banc Resolution in A.M. No. MTJ-02-1438 is a final judgment on the merits rendered by a competent tribunal. The parties in both cases are identical: Executive Judge Basilla as complainant and Judge Becamon, Lolita delos Reyes, and Eddie delos Reyes as respondents. The subject matter and cause of action are also the same, as both complaints are rooted in the respondents’ alleged irregularities in Civil Case No. 288, as cited in the April 5, 2000 Order. The present case is a clear duplication, seeking to relitigate matters already conclusively settled. Applying res judicata promotes judicial economy, prevents vexatious litigation, and stabilizes rights. Therefore, the instant complaint is dismissed.