G.R. No. RTJ-02-1736; June 26, 2003
SPOUSES ARTURO and JOSEFINA DE GUZMAN, Complainants, vs. JUDGE FERNANDO VIL PAMINTUAN, REGIONAL TRIAL COURT, BRANCH 3, BAGUIO CITY, Respondent.

FACTS

The complainants, spouses De Guzman, obtained a demolition order from the Baguio City Mayor against a structure built by Wilson Gomez on their lot. Gomez filed a civil case for specific performance with a prayer for a preliminary injunction before respondent Judge Pamintuan’s court, alleging a promise to grant him a portion of the lot. The judge issued a writ of preliminary injunction upon Gomez’s posting of a bond. Subsequently, the complainants moved to dissolve the writ, contending the bond was defective as the attached clearance pertained to a different insurance company. The bonding company withdrew its bond, and Gomez posted successive replacement bonds, which the Clerk of Court also found defective due to pending liabilities or unauthorized signatories. Despite these defects and the complainants’ motions, Judge Pamintuan denied the motion to dissolve the injunction in an Order dated July 25, 2001.
The complainants then filed this administrative case, charging the judge with gross ignorance of the law, incompetence, favoritism, and misconduct for not dissolving the injunction. They later also filed a motion for his inhibition, which he denied. Both parties submitted the case for decision based on the pleadings.

ISSUE

Whether respondent Judge Fernando Vil Pamintuan is administratively liable for denying the motion to dissolve the writ of preliminary injunction.

RULING

No, the respondent judge is not administratively liable. The Supreme Court dismissed the complaint, reiterating the fundamental policy that an administrative complaint is not the proper remedy for every erroneous order or decision issued by a judge where judicial recourse, such as a motion for reconsideration, appeal, or petition for certiorari, is still available. Disciplinary proceedings are not substitutes for these judicial remedies. The Court emphasized that to hold judges administratively accountable for every error would render the judicial office untenable, as no judge is infallible.
In this case, the complainants did not even file a motion for reconsideration of the assailed Order before resorting to an administrative case, making their complaint premature. For a judge to be held liable for gross ignorance of the law, the erroneous act must be motivated by bad faith, fraud, malice, or dishonesty. The records reveal no such taint in the judge’s denial of the motion to dissolve; his action constituted, at most, an error of judgment correctible through ordinary judicial channels. The allegations of bias and partiality were unsupported by clear and convincing evidence, being based merely on the complainants’ suspicions. The mere filing of an administrative case is also not a valid ground for compelling a judge’s inhibition.