G.R. No. RTJ-00-1568. February 15, 2001.
HON. ROBERT Z. BARBERS, JUANITO DE GUZMAN and LUCIO MARGALLO IV, petitioners, vs. JUDGE PERFECTO A.S. LAGUIO, JR., respondent.

FACTS

An administrative complaint was filed against respondent Judge Perfecto A.S. Laguio, Jr., alleging he knowingly rendered an unjust judgment, among other charges, after he acquitted Lawrence Wang in three consolidated criminal cases. Wang, a Hong Kong national, was arrested in a warrantless operation in May 1996. PARAC agents, acting on information from previously arrested suspects, conducted surveillance and apprehended Wang as he approached his car. A search of the car’s trunk allegedly yielded shabu, cash, scales, and unlicensed firearms. He was charged with violation of the Dangerous Drugs Act, illegal possession of firearms, and violation of the COMELEC gun ban. The prosecution presented its evidence, after which the defense filed a demurrer to evidence.

ISSUE

Whether respondent Judge Laguio, Jr. is administratively liable for gross ignorance of the law or knowingly rendering an unjust judgment in granting the demurrer to evidence and acquitting the accused.

RULING

The Supreme Court dismissed the administrative complaint and exonerated Judge Laguio, Jr. The Court held that a judge cannot be held administratively accountable for every erroneous ruling, as long as he acts in good faith. The essence of a demurrer to evidence is that the court, after assessing the prosecution’s evidence, finds it insufficient to support a conviction. In granting the demurrer, Judge Laguio, Jr. meticulously evaluated the prosecution’s case. He found the warrantless arrest invalid, as it did not fall under any recognized exception under Rule 113 of the Rules of Criminal Procedure. The arrest was not made during the commission of an offense, and the officers lacked personal knowledge that Wang had just committed a crime, relying instead on information from others. Consequently, the subsequent search was likewise invalid, and the evidence obtained—the shabu and firearms—was inadmissible as “fruit of the poisonous tree.” With the prosecution’s evidence rendered inadmissible, there was no competent proof to sustain a guilty verdict. The Court found that the judge’s legal reasoning, while potentially subject to appellate review, was grounded in law and jurisprudence. There was no evidence of bad faith, malice, or corrupt motive. The judge’s actions constituted a legitimate exercise of judicial discretion, not gross ignorance of the law or a deliberate intent to render an unjust judgment.