A.M. No. RTJ-06-2012, August 4, 2006
Ignacio E. Maylas, Jr., Complainant, vs. Judge Manuel L. Sese, Regional Trial Court of Masbate City, Branch 45, Respondent.

FACTS

Complainant Ignacio E. Maylas, Jr. filed an administrative complaint against respondent Judge Manuel L. Sese for gross ignorance of the law and violation of the Rules of Court. The charges stemmed from the judge’s handling of Criminal Case No. 10911. In that case, the accused filed a Motion to Quash solely on the ground that the facts alleged in the information did not constitute an offense. However, in an Order dated October 14, 2003, Judge Sese granted the motion not on the ground raised, but on the distinct ground of lack of probable cause. The public prosecutor’s motion for reconsideration was subsequently denied.
The prosecution elevated the matter to the Court of Appeals via a petition for certiorari. In a Decision dated August 30, 2004, the appellate court granted the petition, annulling and setting aside Judge Sese’s orders for having been issued with grave abuse of discretion. The Court of Appeals found that the judge erred in considering a ground not invoked in the motion to quash, contrary to Section 2, Rule 117 of the Rules of Criminal Procedure, and directed the reinstatement of the criminal case.

ISSUE

Whether respondent Judge Manuel L. Sese is administratively liable for gross ignorance of the law for issuing an order quashing an information on a ground not raised by the accused, which was later reversed by the Court of Appeals.

RULING

No, the respondent judge is not administratively liable. The Supreme Court adopted the findings and recommendation of the Office of the Court Administrator (OCA) to dismiss the complaint for lack of merit. The error attributed to Judge Sese pertains to an exercise of his judicial or adjudicative function. As a settled policy, a judge cannot be subjected to administrative sanction for an erroneous order or decision rendered in good faith, in the absence of fraud, dishonesty, corruption, bad faith, or deliberate intent to do an injustice. Judicial errors, no matter how grave, are not correctible through administrative proceedings but through the appropriate judicial remedies, such as a motion for reconsideration or appeal, which were availed of in this case.
The Court emphasized that the filing of an administrative complaint is not the proper remedy to correct actions of a judge perceived to be erroneous where sufficient judicial remedies exist. The fact that the Court of Appeals found grave abuse of discretion does not automatically translate to administrative liability. For such liability to attach, the error must be gross, patent, malicious, or committed in bad faith. Here, the complaint itself did not impute malice or bad faith, and the respondent judge asserted he acted after careful evaluation. In the absence of contrary proof, he is presumed to have acted in good faith. Therefore, the administrative case was dismissed.