G.R. No. OCA IPI No. 12-204-CA-J. March 11, 2014.
AMA LAND, INC. (REPRESENTED BY JOSEPH B. USITA), complainant, vs. COURT OF APPEALS ASSOCIATES JUSTICES HON. DANTON Q. BUESER, HON. SESINANDO E. VILLON AND HON. RICARDO R. ROSARIO, respondents.

FACTS

AMA Land, Inc. (AMALI) filed an administrative complaint against Court of Appeals Associate Justices Danton Q. Bueser, Sesinando E. Villon, and Ricardo R. Rosario. The complaint charged them with knowingly rendering an unjust judgment, gross misconduct, and violation of their oaths of office in relation to their promulgation of a decision in C.A.-G.R. SP No. 118994, a case involving Wack Wack Residents Association, Inc. (WWRAI) and AMALI. The underlying case originated from AMALI’s petition for an easement of right of way to access its condominium project via Fordham Street. The RTC initially granted AMALI a writ of preliminary mandatory injunction. WWRAI later filed a petition for certiorari in the CA, which eventually granted WWRAI’s petition. AMALI, alleging conspiracy between the respondent Justices and WWRAI’s counsel, claimed the decision was rendered in bad faith to favor WWRAI. This was the second administrative complaint AMALI filed against the same Justices concerning the same case. AMALI had also filed a petition for review on certiorari (G.R. No. 202342) in the Supreme Court challenging the CA’s decision.

ISSUE

Are the respondent Justices liable for knowingly rendering an unjust judgment and for violating Canon 1, Rule 1.01; Canon 10, Rules 10.01 and 10.03 of the Code of Professional Responsibility; and Section 27, Rule 138 of the Rules of Court?

RULING

No. The Supreme Court En Banc dismissed the administrative complaint for utter lack of merit. The Court held that in administrative proceedings, the complainant bears the burden of proving the allegations by substantial evidence. For charges equivalent to a criminal offense, like knowingly rendering an unjust judgment, culpability must be proven beyond reasonable doubt. AMALI failed to meet this burden. Knowingly rendering an unjust judgment under Article 204 of the Revised Penal Code requires proof beyond reasonable doubt that the judgment was not only patently contrary to law or evidence but was made with a conscious and deliberate intent to do an injustice (bad faith, malice, corrupt motive). Mere errors of judgment or interpreting the law incorrectly do not constitute administrative liability. Furthermore, the determination of whether a judgment is unjust can only be made by a superior court exercising appellate or supervisory jurisdiction, not through an administrative complaint. The Court condemned the practice of filing administrative complaints against judges as a substitute for exhausted judicial remedies, noting it subverts judicial independence. The Court found AMALI prone to such actions, having filed a prior similar complaint which was also dismissed. Consequently, the Court ordered Joseph B. Usita and AMALI’s Board of Directors to show cause why they should not be punished for indirect contempt for degrading the judicial office and interfering with the performance of judicial duties.