AM MTJ 95 1045; (November, 1995) (Digest)
A.M. No. MTJ-95-1045. November 28, 1995. DR. LUIS C. BENGZON, complainant, vs. JUDGE LUISITO ADAOAG, respondent.
FACTS
Complainant Dr. Luis C. Bengzon secured a favorable judgment in an ejectment case before the Municipal Trial Court (MTC) of Camiling, Tarlac, presided by Judge Eleanor De Jesus. After the defendants failed to vacate, complainant filed a motion for demolition. Judge De Jesus retired without resolving the motion, and respondent Judge Luisito Adaoag inherited the case. Judge Adaoag issued a resolution holding the motion for demolition in abeyance pending the outcome of a related tenancy case before the Department of Agrarian Reform Adjudication Board (DARAB). The DARAB case was filed by Romeo Fernandez, who claimed ownership of the disputed land via a Certificate of Land Transfer under P.D. No. 27 and had obtained a Temporary Restraining Order against the ejectment.
Complainant moved for reconsideration, arguing that Romeo Fernandez was bound by the ejectment judgment as the defendants were his mother and sister, and that his certificate was fraudulent or pertained to another property. Respondent judge denied the motion. Complainant then filed this administrative case, accusing Judge Adaoag of ignorance of the law, incompetence, bias, and abuse of authority for deferring to the DARAB proceeding, asserting the tenancy issue was already resolved when the MTC earlier denied a motion to dismiss.
ISSUE
Whether respondent Judge Luisito Adaoag is administratively liable for gross ignorance of the law, incompetence, bias, and abuse of authority for holding in abeyance the resolution of a motion for demolition in an ejectment case pending the outcome of a DARAB tenancy case.
RULING
The Supreme Court dismissed the administrative complaint. The Court emphasized that administrative charges are not the proper remedy to correct judicial errors, as complainant had already filed a petition for certiorari in the Regional Trial Court to assail the questioned resolution. For a judge to be held administratively liable for ignorance of the law, the error must be so gross, patent, and deliberate as to imply bad faith, malice, or a conscious intent to render an unjust order.
The Court found no such gross ignorance or abuse here. Respondent judge acted based on specific facts: Romeo Fernandez, who was not a party to the ejectment case, held a Certificate of Land Transfer, had fully paid the Land Bank, and had a pending DARAB case where a TRO was issued. Deferring action on the demolition under these circumstances was a prudent exercise of judicial discretion to avoid potential conflict with the agrarian reform case. Any error in judgment, if at all, constituted at most an error of jurisdiction or grave abuse of discretion correctible by judicial appeal, not by administrative sanction. The charges of bias and hostility, based on perceived slights during court greetings, were unsubstantiated and did not demonstrate partiality.