G.R. No. RTJ-03-1755. July 3, 2003
JUDGE SALVADOR P. DE GUZMAN (Ret.), complainant, vs. JUDGE AMALIA F. DY, Regional Trial Court, Branch 213, Mandaluyong City, respondent.

FACTS

Complainant, a retired judge and practicing lawyer, filed an administrative complaint for Grave Misconduct and Conduct Prejudicial to the Judiciary against respondent Judge Amalia F. Dy. The complaint stemmed from a criminal case for Violation of B.P. Blg. 22 filed by complainant’s client, Lourdes Reyes, against Emmanuel Cosico. The Metropolitan Trial Court (MeTC) initially suspended proceedings due to a prejudicial question raised in a civil action for specific performance filed by Cosico, but later set aside the suspension and issued a warrant. Cosico then filed a petition for certiorari before respondent judge’s court, which issued a Temporary Restraining Order and later a writ of preliminary injunction to enjoin the arraignment.
Complainant argued that respondent judge’s orders were erroneous under Rule 111, Section 7 of the Revised Rules of Criminal Procedure, which requires the civil action to be previously instituted to constitute a prejudicial question. He insinuated that the orders were improperly favorable to Cosico’s counsel, Atty. Manuel Cosico, whom he alleged was the judge’s “compadre.” Respondent judge denied any personal relationship and maintained her orders were legally sound, applying the 1985 Rules of Criminal Procedure then in effect, which did not require the civil action to precede the criminal one for a prejudicial question to arise.

ISSUE

Whether respondent Judge Amalia F. Dy is administratively liable for Grave Misconduct and Conduct Prejudicial to the Best Interest of the Judiciary based on her issuance of the assailed orders in the certiorari petition.

RULING

No, respondent judge is not administratively liable. The Supreme Court dismissed the complaint for lack of merit. In administrative proceedings, the complainant bears the burden of proving the allegations by substantial evidence. Here, the charges were based merely on suspicion and speculation regarding an alleged personal relationship, without any competent evidence of bad faith, malice, or corrupt motive. The presumption of regularity in the performance of official duties stands in the absence of contrary proof.
The Court emphasized that for a judge to be held administratively accountable for judicial actions, it must be shown beyond reasonable doubt that the act was not merely erroneous but was rendered with a conscious and deliberate intent to do an injustice. Respondent judge’s interpretation and application of the procedural rules on prejudicial questions, even if potentially debatable, constitute at most an error of judgment. Errors of judgment, when made in good faith, do not warrant administrative sanction. The proper remedy for any perceived legal error lies in judicial appeals, not in an administrative complaint.