G.R. No. L-46845; April 27, 1990
Hon. PEDRO T. SANTIAGO, Judge, Court of First Instance, Branch 2, Bataan, petitioner, vs. COURT OF APPEALS, LUZMINIA T. BAGALAWIS, AMADO SAMSON, JULIETA T. BAGALAWIS, CESAR SICAT, CARLOS T. BAGALAWIS, FIDES ARMENGOL and the EXPORT PROCESSING ZONE AUTHORITY, respondents.

FACTS

This case originated from an expropriation proceeding filed by the Export Processing Zone Authority (EPZA) before the Court of First Instance of Bataan, Branch 2, presided by petitioner Judge Pedro T. Santiago. The subject was two parcels of land owned by the private respondents. While the case was pending for the determination of just compensation, the EPZA and the landowners reached an amicable settlement, which included the sale of an additional parcel of land not originally subject of the expropriation. Consequently, the parties moved for the dismissal of the case. Judge Santiago, however, denied the motion and required the submission of the deeds of sale for his scrutiny.
Examining the deeds, Judge Santiago found that the compensation amounts agreed upon were grossly higher than both the market values declared by the owners and the values determined by the Provincial Assessor. He ruled that the agreement violated Presidential Decree No. 76, which mandated that just compensation be based on the lower value between the owner’s declaration and the assessor’s valuation. Consequently, in an order dated October 29, 1975, he rejected the amicable settlement as invalid and set the case for further proceedings. The Court of Appeals later reversed this order and upheld the validity of the settlement.

ISSUE

Whether Judge Pedro T. Santiago possesses the legal capacity to file the present petition for review assailing the Court of Appeals’ decision that reversed his order.

RULING

The Supreme Court denied the petition, ruling that Judge Santiago lacks the legal capacity to sue. The legal logic is grounded in procedural propriety and the defined role of a judge within the judicial hierarchy. While Section 1 of Rule 45 allows a party to appeal via certiorari, Judge Santiago was not a party in the substantive expropriation case between EPZA and the landowners. His inclusion as a respondent in the certiorari proceeding before the Court of Appeals was merely nominal and procedural, as required when a court’s order or jurisdiction is challenged. The Court emphasized that a judge, in his official capacity, is not an active combatant or a real party-in-interest in such appellate reviews. Citing precedent, the Court held that a judge whose order is under attack is merely a nominal party and a decent regard for the judicial hierarchy bars a judge from suing to reverse an unfavorable appellate decision. His duty is to decide, not to litigate. Therefore, regardless of his motives—which the Court noted were ostensibly to protect the government from an allegedly inequitable contract—Judge Santiago overstepped his role by filing this petition as an adversarial party seeking affirmance of his own order. The petition was dismissed on this procedural ground.