G.R. No. L-4198
JUAN MERCADO, plaintiff-appellee, vs. JOSE ABANGAN, defendant-appellant.
March 30, 1908

FACTS:
Plaintiff Juan Mercado brought an action for damages against defendant Jose Abangan, a Justice of the Peace. Mercado alleged that Abangan unlawfully deprived him of possession of a parcel of land.

The facts show that in an earlier unlawful detainer action where Mercado was the defendant, Abangan, as Justice of the Peace, rendered judgment against Mercado. A few days after this judgment, specifically on the morning of April 11, 1905, Abangan sent Mercado a letter ordering him not to enter or touch the land “pending the appeal.” On the evening of the same day, Mercado perfected his appeal from the unlawful detainer judgment, which was allowed, and the appeal bonds approved by Abangan.

Sometime thereafter, while the appeal in the unlawful detainer action was still pending, Abangan issued warrants of arrest on two separate complaints (one for robbery and one for larceny) against Mercado’s servants who had entered the land to collect cocoanuts and other products. For the robbery complaint, Abangan held a preliminary investigation and remanded the accused to the Court of First Instance (CFI) for trial. The CFI later dismissed the complaint upon motion of the provincial fiscal.

Mercado claimed that Abangan acted in bad faith and in excess of his authority by issuing the unlawful order and the criminal warrants, thereby depriving him of possession and causing damages. The trial court found in favor of Mercado, ruling that Abangan acted in bad faith and in excess of his authority, and awarded Mercado P567.50 in damages. Abangan appealed.

ISSUE:
Was the defendant Justice of the Peace liable for damages for unlawfully depriving the plaintiff of land possession, either through an order prohibiting entry or through the issuance of criminal warrants against plaintiff’s servants?

RULING:
No. The Supreme Court reversed the judgment of the trial court, finding the defendant Justice of the Peace not liable for damages.

1. Regarding the order forbidding entry: The Court held that the order issued by Abangan prohibiting Mercado from entering the land was effectively vacated on the same day it was issued (April 11, 1905), when Mercado perfected his appeal in the unlawful detainer case. The perfection of the appeal necessarily vacated the judgment and all proceedings in the justice of the peace court, including that order. The Court found no evidence of damages suffered by Mercado during the few hours the order was in effect. Furthermore, any subsequent belief by Mercado that the order remained in force, despite the appeal, was due to his own ignorance of his rights, for which the Justice of the Peace cannot be held liable.

2. Regarding the issuance of criminal warrants: The Court ruled that Abangan was clearly acting within his legal powers and jurisdiction when he issued the warrants of arrest based on complaints filed in the usual form. The mere fact that the criminal complaints were later dismissed in the Court of First Instance does not, by itself, prove bad faith or error on the part of the Justice of the Peace in conducting the preliminary investigation or remanding the accused for trial. A fundamental principle of jurisprudence is that judges, whether of higher or lower courts, are not bound at the peril of an action for damages to decide correctly on matters of law or fact, but to decide according to their own convictions, exercising the jurisdiction vested in them by law. The Court found no sufficient evidence to sustain the trial court’s finding of bad faith in the criminal proceedings.