G.R. No. 177105 , August 12, 2010
JOSE REYES y VACIO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Belen Lopez Vda. de Guia was the registered owner of agricultural land. Her son, Carlos, forged a deed of sale to transfer the title to himself, after which he sold it to Ricardo San Juan. Belen filed a civil case for reconveyance. Initially dismissed, her appeal was reinstated, culminating in a 1986 IAC decision declaring the forged sale void, ordering reconveyance to Belen, and reinstating her title. This judgment became final. Despite this, Ricardo had earlier executed a deed of reconveyance to the tenant-farmers, who obtained titles. Belen subsequently filed an ejectment case against the tenants before the DARAB.
As the Provincial Adjudicator, petitioner Jose Reyes rendered a 1993 DARAB decision dismissing Belen’s complaint and affirming the tenants’ titles. He ruled that the IAC decision was not binding on the DARAB as it was not a party to that case, and that the tenants were purchasers in good faith. This effectively nullified the final IAC judgment in favor of Belen. Reyes was then charged with violation of Section 3(e) of R.A. 3019 and usurpation of judicial functions under Article 241 of the Revised Penal Code.

ISSUE

Whether petitioner Reyes is guilty of the crimes charged for rendering the DARAB decision that disregarded a final and executory judgment of a superior court.

RULING

Yes, the Sandiganbayan’s conviction is affirmed. For violation of R.A. 3019, Section 3(e), the elements are: the accused is a public officer; the act was done in the discharge of official functions; through manifest partiality, evident bad faith, or gross inexcusable negligence; causing undue injury or giving unwarranted benefits. Reyes, as a public officer adjudicator, acted with evident bad faith. A final judgment is immutable and binding on all parties and their successors-in-interest. The IAC decision had long become final and executory, constituting res judicata. By ignoring this final judgment and ruling on the validity of titles already declared void, Reyes knowingly rendered an unjust decision. His claim of good faith is untenable; as a lawyer and adjudicator, he was duty-bound to respect final judgments of superior courts.
For usurpation of judicial functions under Article 241 of the RPC, the elements are: the offender is a public officer; he knowingly assumes a judicial power; that power belongs to the judiciary. Reyes’s act of effectively annulling a final judgment of the IAC, a judicial tribunal, constituted an unlawful assumption of a judicial power vested solely in the courts. The DARAB’s jurisdiction is limited to agrarian disputes; it has no authority to review, reverse, or declare void final judgments of regular courts. His decision was a clear usurpation of judicial authority, undermining judicial finality and the rule of law.