AM SC 96 1; (December, 1996) (Digest)
A.M. No. SC-96-1 December 23, 1996
Damaso S. Flores, complainant, vs. Hon. Bernardo P. Abesamis, Regional Trial Court Branch 85, Quezon City (now Deputy Administrator), respondent.
FACTS
The administrative case arose from a protracted civil litigation for collection of a sum of money. The parties, Rolando Ligon and Damaso Flores, entered into a court-approved compromise agreement. Upon Flores’s alleged default, the trial court issued orders for execution. Flores appealed, contending the orders altered the compromise terms. During the appeal, Ligon purchased the subject property, the Parañaque Cockpit Stadium, from the lessor’s heirs. The trial court, then presided over by Judge Bernardo Abesamis, later issued an order halting the execution of a final and executory judgment in favor of Flores. The order was based on Ligon’s supervening ownership of the property, which the court deemed a justification for allowing Ligon to retain possession despite the final judgment ordering restoration of possession to Flores.
ISSUE
Whether respondent Judge Bernardo P. Abesamis is administratively liable for issuing orders that allegedly disregarded final and executory judgments.
RULING
The Supreme Court dismissed the administrative complaint for utter lack of merit. The legal logic is clear: for a judge to be held administratively liable, the acts complained of must be proven to have been done with bad faith, malice, or corrupt intent. Mere errors of judgment, absent proof of such ill motive, are not a ground for administrative sanction. In this case, the Court found that all orders issued by Judge Abesamis, which were challenged by complainant Flores, had been subsequently reviewed and affirmed as correct by both the Court of Appeals and the Supreme Court in related petitions. Specifically, the Supreme Court had already ruled in the main civil case that Ligon’s supervening acquisition of ownership constituted an exceptional circumstance that rendered the execution of the final judgment impossible, thereby validating the trial court’s orders. Since the questioned judicial actions were ultimately upheld as legally sound, they cannot be a basis for finding administrative fault. The Court emphasized that judges should not be subjected to harassment for performing their official duties, especially when their rulings are later sustained by higher tribunals.