Ipi 15 227 CA J; (November, 2016) (Digest)
G.R. No. I.P.I. No. 15-227-CA-J. November 29, 2016
RE: VERIFIED COMPLAINT OF DOLORA CADIZ KHANNA AGAINST HON. EDGARDO L. DELOS SANTOS, ET AL.
FACTS
Complainant Dolora Cadiz Khanna filed an administrative complaint for corruption and extortion against several judges and a sheriff. Khanna alleged that in a civil case for injunction she filed before the Regional Trial Court (RTC) of Kalibo, Aklan, presided by respondent Judge Ronald H. Exmundo, the judge demanded and received money through an intermediary, Atty. Mateo Hachuela, in exchange for issuing a Temporary Restraining Order (TRO) and later for denying a motion for execution. She presented photocopies of checks and text messages as evidence. Khanna further claimed that after an adverse Court of Appeals (CA) resolution, she met with respondent Judge Fricia C. Gomez-Guillen of the Metropolitan Trial Court (MeTC), Manila, her husband, and respondent Sheriff Apolinar S. Juan. This group allegedly offered to influence the CA justices for a fee of Twelve Million Pesos to secure a favorable ruling.
ISSUE
Whether the respondents should be held administratively liable based on the allegations and evidence presented in the complaint.
RULING
The Supreme Court dismissed the complaint against CA Justices Edgardo L. Delos Santos, Marilyn B. Lagura-Yap, and Jhosep Y. Lopez for utter lack of merit. The Court emphasized the doctrine of judicial immunity, which shields judges from liability for official judicial acts performed in good faith. The allegations against the CA justices pertained solely to their adjudicatory function in granting a motion for execution pending appeal. There was no evidence, only bare accusations, that their decision was rendered with malice, fraud, or corruption. The Court cannot subject judges to administrative inquiry for every unfavorable ruling, as this would undermine judicial independence.
However, the Court found the complaint against Judge Exmundo, Judge Gomez-Guillen, and Sheriff Juan sufficient to warrant a formal investigation. The evidence pertaining to them, including details of monetary demands and meetings allegedly for the purpose of influencing court proceedings, if proven, would constitute serious administrative offenses that tarnish the judiciary’s integrity. Their alleged actions, though purportedly done outside court confines, directly relate to their official functions and exploit the judicial process. Consequently, the Court re-docketed the complaint as a regular administrative matter against these three respondents and directed the Office of the Court Administrator to conduct a full investigation and submit a report and recommendation.
