G.R. No. RTJ-05-1935. July 29, 2005
Evelyn Suarez-De Leon vs. Judge Santiago G. Estrella, Pairing Judge, Regional Trial Court, Branch 67, Pasig City

FACTS

Complainant Evelyn Suarez-De Leon was a plaintiff in Civil Case No. 51203 for annulment of a judicial sale. The Supreme Court, in its final and executory 1992 Decision in G.R. No. 94918, reversed the Court of Appeals and ordered the reinstatement of the civil case solely to determine the portion of the disputed properties belonging to the petitioners (complainant and her siblings) and to annul the sale of that portion. In 1996, the trial court issued an order to implement this mandate. However, in 2000, respondent Judge Santiago Estrella, as pairing judge, issued an order dismissing the same civil case. He relied on the doctrine in Heirs of Yaptinchay vs. Del Rosario, which states that declaration of heirship must be made in a special proceeding, not an ordinary civil action. The complainant charged the judge with serious misconduct and gross ignorance of the law for disregarding the Supreme Court’s final decision.

ISSUE

Whether respondent Judge Santiago Estrella is administratively liable for gross ignorance of the law or misconduct for dismissing Civil Case No. 51203 contrary to a final and executory Supreme Court decision.

RULING

The Supreme Court dismissed the administrative complaint for insufficiency of evidence to prove bad faith, malice, or corrupt motive. However, it found that respondent judge committed a legal error warranting admonition. The Court explained that the final 1992 decision in G.R. No. 94918 constituted the “law of the case.” This doctrine means that a ruling made by an appellate court on a question of law becomes binding and must be followed in all subsequent proceedings in the same case. The Supreme Court had already ruled that the complainant and her siblings were heirs and co-owners; the only remaining task for the trial court was to determine their specific share and annul the sale thereof. Respondent judge’s reliance on Yaptinchay was misplaced because that general doctrine could not override the specific, final mandate in G.R. No. 94918, which did not require a separate special proceeding for heirship declaration. The judge’s duty was to obey the final order, conduct hearings to determine the shares, and annul the sale accordingly. His failure to do so demonstrated a lack of diligence and carefulness in applying settled law. The Court directed the reinstatement of Civil Case No. 51203 for proceedings consistent with its 1992 decision.