G.R. No. 132446. March 1, 2001
Sofronio Dayot, complainant, vs. Judge Rodolfo B. Garcia, Municipal Circuit Trial Court, Calavatra-Toboso, Negros Occidental, respondent.

FACTS

Complainant Sofronio Dayot was convicted of Grave Slander by respondent Judge Rodolfo Garcia. The conviction was affirmed with modifications by the Regional Trial Court and the Court of Appeals. Dayot elevated the case to the Supreme Court via a petition for review, docketed as G.R. No. 132446. The Court’s Second Division denied due course to the petition in a Resolution dated March 11, 1998. Dayot filed a Motion for Reconsideration on April 17, 1998. While this motion was pending before the Supreme Court, respondent judge issued a warrant for Dayot’s arrest and ordered his detention on May 4, 1998. The Supreme Court subsequently denied the Motion for Reconsideration with finality on July 6, 1998.
In this administrative complaint, Dayot charges Judge Garcia with misconduct, abuse of authority, and oppression for issuing the arrest warrant despite the pending motion for reconsideration. He further alleges that the judge failed to act on his Motion to Lift the warrant and, in an Order dated November 6, 1998, discredited his service of sentence from May to November 1998 after receiving an oral complaint that Dayot was serving his sentence outside the prison cell.

ISSUE

Whether respondent Judge Rodolfo B. Garcia is administratively liable for his actions in issuing the warrant of arrest and the Order discrediting the complainant’s service of sentence.

RULING

Yes, the respondent judge is administratively liable, but only for issuing the Order of November 6, 1998 without due process. The Court, adopting the recommendation of the Court Administrator, found the charge regarding the warrant of arrest to be without merit for administrative purposes. The act of issuing the warrant while a motion for reconsideration was pending before the Supreme Court, and the subsequent denial of the Motion to Lift it, involved an exercise of judicial discretion. Any error therein is a judicial matter not subject to administrative correction, as the proper remedy was judicial appeal. The record also shows the judge did act on the motion by issuing an Order of denial on June 25, 1998.
However, the respondent judge is liable for the Order dated November 6, 1998. This order, issued based on an oral complaint, decreed that Dayot’s period of service outside the jail cell should not be credited to his sentence. The Supreme Court held that this was done without a hearing or notice to the accused or his counsel. While a judge’s desire to prevent corruption or special treatment for prisoners is understandable, it does not justify abusing judicial discretion or violating due process. The unilateral discrediting of the service period without affording Dayot an opportunity to be heard constitutes a clear denial of due process. This act demonstrates a failure to understand the limitations of judicial power and betrays ignorance of fundamental due process principles. While judges enjoy relative immunity for erroneous judgments, this does not extend to arbitrary or negligent acts that violate basic rights. Accordingly, the Court imposed a fine of Five Thousand Pesos (P5,000.00) on Judge Garcia with a stern warning.