G.R. No. 101041 & G.R. No. 101296, November 13, 1991
Hon. Judge Adriano R. Villamor, petitioner, vs. Hon. Judge Bernardo LL. Salas and George Carlos, respondents. / Hon. Judge Adriano R. Villamor, petitioner, vs. Antonio T. Guerrero and Hon. Peary G. Aleonar, Presiding Judge of RTC, Branch 21, Region VII, Cebu City, respondents.

FACTS

Judge Adriano Villamor presided over Civil Case No. B-398 and related criminal cases for qualified theft filed by George Carlos against Gloria Naval. After deciding the civil case in Naval’s favor, Judge Villamor dismissed the criminal cases. Carlos then filed an administrative complaint against the judge, which the Supreme Court dismissed. Subsequently, Carlos filed a civil damages case against Judge Villamor for allegedly rendering an unjust judgment in dismissing the criminal cases. Upon being served the summons for this damages suit, Judge Villamor issued an order of direct contempt against Carlos and his lawyer, Atty. Antonio Guerrero, in the criminal cases. The Supreme Court annulled this contempt order.
Undeterred, Carlos and Guerrero filed separate civil actions for damages against Judge Villamor, alleging he knowingly rendered an unjust contempt order. These cases were raffled to different RTC branches presided by Judges Bernardo Salas and Peary Aleonar. Judge Villamor moved to dismiss both suits, but his motions were denied by the respective judges, prompting him to file these consolidated petitions for certiorari and prohibition.

ISSUE

Whether Regional Trial Court Judges Salas and Aleonar may take cognizance of the civil actions for damages against Judge Villamor for allegedly rendering an unjust order of contempt.

RULING

No, the respondent judges cannot take cognizance of the actions. The Supreme Court granted the petitions and ordered the dismissal of the civil cases. The legal logic is anchored on the principle of co-equal jurisdiction and judicial immunity. The various branches of the Regional Trial Court are co-equal and coordinate courts; no branch has the authority to review, interfere with, or pass judgment upon the lawful orders or judgments of another branch. To allow Judges Salas and Aleonar to proceed would effectively permit a court of equal rank to review and scrutinize the judicial act of a colleague, which is a function reserved exclusively for appellate courts.
Furthermore, for a judge to be held civilly liable for a judicial act, such as rendering an order, it must be shown that the error was committed deliberately, in bad faith, or with malice. The Supreme Court, in annulling the contempt order, made no finding that Judge Villamor acted with malice or conscious intent to commit an injustice. At most, the annulled order constituted an error of judgment, for which a judge enjoys immunity from civil suit in the absence of a clear showing of bad faith, dishonesty, or corrupt purpose. The petitions were therefore granted, and the temporary restraining orders were made permanent.