A.M. No. MTJ-03-1476; February 4, 2003
BENITO ANG, complainant, vs. JUDGE REINATO G. QUILALA, CLERK OF COURT ZENAIDA REYES-MACABEO and CLERK III LOUIE MACABEO, MeTC, Manila, respondents.

FACTS

Complainant Benito Ang faced multiple estafa and Batas Pambansa Blg. 22 charges. He attended his arraignment in the Regional Trial Court but failed to appear at the scheduled arraignment in the Metropolitan Trial Court (MeTC), Branch 26, Manila, presided by respondent Judge Reinato G. Quilala. Consequently, Judge Quilala issued a warrant for his arrest and ordered the confiscation of his surety bond. Ang filed a motion to lift the warrant. He alleged that during this process, respondent Clerk III Louie Macabeo solicited P30,000.00 from him, implying he could help with the case. Ang’s lawyer advised against giving money. Judge Quilala later denied Ang’s motion for reconsideration.
Subsequently, a bench warrant was served on Ang, leading to his brief detention after he failed to post a reinstated higher bail bond. His counsel filed a Very Urgent Motion for Reconsideration the same afternoon, which Judge Quilala also denied. Ang then filed this administrative complaint, charging the judge and the two court clerks with acting in concert to extort money from him.

ISSUE

Whether respondents Judge Reinato G. Quilala, Clerk of Court Zenaida Reyes-Macabeo, and Clerk III Louie Macabeo are administratively liable for extortion and for the alleged improper issuance of court orders.

RULING

The Court DISMISSED the administrative complaint for lack of merit. On the charge of extortion, the Court found no concrete evidence presented by complainant Ang to substantiate his claims against the court officers. The denials by the clerks were deemed credible, as no proof corroborated the alleged solicitation.
Regarding Judge Quilala’s judicial actions, the Court ruled he is not administratively liable. The settled doctrine shields judges from administrative responsibility for judicial acts done within their legal powers and jurisdiction, provided there is no showing of gross error, bad faith, malice, or fraud. Here, the judge’s denial of the motions was a proper exercise of judicial discretion. The first motion was denied due to Ang’s unexcused absence from arraignment. The second urgent motion was correctly denied for procedural defects, including lack of proof of service to the prosecutor, and because the reinstatement of the original bail bond was in accordance with the Department of Justice Bailbond Guide. The record was devoid of any indication that the judge was motivated by ill-will, dishonesty, or a conscious intent to do wrong. Bad faith is not presumed and must be proven by the complainant, which Ang failed to do. Thus, the acts complained of constituted, at most, mere errors of judgment, not gross or patent errors incurred with evident bad faith.