G.R. No. 194111, December 10, 2013
RE: LETTERS OF LUCENA B. RALLOS and RE: COMPLAINT FILED BY LUCENA B. RALLOS

FACTS

The consolidated administrative cases stem from a protracted dispute over just compensation for land owned by the Heirs of Vicente Rallos, including complainant Lucena B. Rallos, and taken by Cebu City. After the Regional Trial Court (RTC) ruled in favor of the heirs, its decisions became final and executory. Cebu City later filed a petition for annulment of judgment (CA-G.R. SP No. 06676) before the Court of Appeals (CA), alleging the discovery of a 1940 compromise agreement (convenio) showing the land was donated, and claiming extrinsic fraud by the heirs for concealing it. The CA’s 18th Division, composed of Justices Abarintos, Hernando, and Paredes, issued a resolution noting formal defects in the petition and requiring Cebu City to rectify them. The case was subsequently re-raffled to a new division.
Complainant Rallos filed administrative charges against the three justices of the 18th Division, alleging they deliberately delayed the case by issuing the defect-resolution to allow Cebu City to correct its petition, thereby aiding the city’s allegedly frivolous suit. In a related matter, Rallos also charged Justices Ingles, Maxino, and Manahan of the new division, alleging impropriety in their voluntary inhibition from the re-raffled case without notifying all parties, which she claimed violated procedural rules and demonstrated bias.

ISSUE

Whether the respondent Justices of the Court of Appeals are administratively liable for their official actions in handling the petition for annulment of judgment.

RULING

The Supreme Court dismissed all complaints for lack of merit. On the first complaint, the Court held that the act of the 18th Division in pointing out curable formal deficiencies in Cebu City’s petition was a legitimate exercise of judicial discretion and a routine procedural step. There was no evidence of malice, fraud, or dishonesty; the justices were merely performing their duty to ensure compliance with procedural rules. Judicial officers cannot be held administratively accountable for acts performed in good faith in the course of their official functions, as long as they are done within the bounds of law and jurisprudence.
Regarding the second complaint, the Court found that the subsequent division’s voluntary inhibition, based on a colleague’s prior participation in a related case, was a valid exercise of discretion to dispel any suspicion of partiality. While the Court acknowledged that the parties should have been formally notified of the inhibition, this procedural lapse did not, by itself, constitute gross ignorance of the law or warrant administrative sanction absent proof of corrupt motive or bad faith. The overriding principle is that judges should not be subjected to liability for any of their official acts, provided they act in good faith, to preserve judicial independence.