A.M. No. RTJ-03-1766; March 28, 2003
Linda M. Sacmar, complainant, vs. Judge Agnes Reyes-Carpio, Regional Trial Court, Branch 261, Pasig City, respondent.

FACTS

Complainant Linda Sacmar was the private offended party in Criminal Case No. 17941 for Grave Threats, where the Metropolitan Trial Court (MeTC) convicted accused Zoren Legaspi and sentenced him to four months of arresto mayor with moral damages. The accused appealed to the Regional Trial Court (RTC), where the case was raffled to respondent Judge Agnes Reyes-Carpio. In her decision dated February 21, 2000, respondent judge modified the MeTC ruling by convicting the accused only of the lesser crime of Other Light Threats under Article 265 of the Revised Penal Code, thereby reducing the penalty to thirty days of arresto menor and lowering the moral damages.
Sacmar filed an administrative complaint, alleging that respondent judge knowingly rendered an unjust judgment under Article 204 of the Revised Penal Code and violated Section 3(e) of R.A. No. 3019 . She claimed the judge exhibited manifest partiality by disregarding evidence to downgrade the conviction, affording unwarranted benefit to the accused and causing her undue injury. Respondent judge denied the charges, asserting she acted in good faith based on her evaluation of the facts and circumstances, and noted the decision was already under review by the Court of Appeals.

ISSUE

Whether respondent Judge Agnes Reyes-Carpio is administratively liable for knowingly rendering an unjust judgment and for manifest partiality.

RULING

No, respondent judge is not administratively liable. The Supreme Court dismissed the complaint for lack of merit, agreeing with the Office of the Court Administrator’s recommendation. Judicial acts pertaining to a judge’s official functions are generally not subject to disciplinary action unless committed with fraud, dishonesty, corruption, or bad faith. A charge of knowingly rendering an unjust judgment requires proof beyond reasonable doubt that the decision was not only unjust but rendered with a conscious and deliberate intent to perpetrate an injustice. Mere error in judgment or interpretation of law, absent proof of malice or corrupt motive, does not constitute an administrative offense.
The Court found that complainant failed to satisfactorily demonstrate that respondent judge acted in bad faith or with deliberate intent to cause an injustice. The modification of the conviction, while differing from the MeTC’s interpretation, represented a judicial assessment of the evidence and applicable law. The availability of judicial remedies, such as the pending appeal before the Court of Appeals, underscores that administrative complaints are not alternative or cumulative to judicial review, especially when the challenged judgment has not been finally declared erroneous by a higher court. Thus, absent clear evidence of malicious intent, respondent judge’s actions fall within the scope of judicial discretion and are protected by the presumption of good faith in the performance of official duties.