Case Digest (G.R. No. 7317)
Facts:
Emilia Alzua and Ignacio Arnalot v. E. Finley Johnson, G.R. No. 7317, January 31, 1912, the Supreme Court En Banc, Carson, J., writing for the Court.
Plaintiffs Emilia Alzua and Ignacio Arnalot (plaintiffs/appellants) sued Justice E. Finley Johnson (defendant/appellee), then an Associate Justice of the Supreme Court of the Philippine Islands, alleging that Johnson maliciously and falsely misstated facts in written opinions and otherwise intervened improperly in two prior appeals (reported in the records as causes Nos. 4017 and 5719), thereby causing this Court to enter erroneous judgments that forced Alzua to pay or to sell property to satisfy a judgment and produced alleged damages totaling tens of thousands of pesos.
The antecedent litigation involved (1) cause No. 4017 — injunction proceedings brought by Manuel and Federico Soler (the minors) claiming ownership/possession of partnership merchandise levied by the sheriff to satisfy an Alzua judgment, and (2) cause No. 5719 — a suit by the same minors against the sheriff, Alzua and her indemnitors concerning the proceeds of the sheriff’s sale. The record showed that Alzua had procured a sheriff’s indemnity bond and obtained possession of proceeds; the minors claimed a preferred credit under the partnership articles. On an agreed statement of facts the Court of First Instance dismissed the minors’ injunction petition; the Supreme Court initially filed a memorandum order (March 27, 1907) that, as entered, read “affirmed,” but while the Court was in vacation Justice Johnson (acting as vacation justice) provisionally struck out “affirmed,” substituted “revoked/reversed,” and ordered suspension of entry/execution pending the return of the record. The full Court later considered and ratified the amendment and ultimately the Supreme Court rendered opinions adjudicating the minors’ preferred-credit claim and directed judgment that resulted in Alzua and her bondsmen being held to account for sums the minors were found entitled to. Alzua paid the judgment (allegedly P12,000) and sold an interest in property to satisfy it, claiming resulting losses and seeking large actual, special and punitive damages from Justice Johnson.
Alzua then filed a civil action in the Court of First Instance of Manila against Johnson for civil damages, charging willful fabrication and bad-faith misstatements in Johnson’s opinions, surreptitious amendment of the memorandum order while the Court was on vacation, and other malicious acts. The trial court sustained a demurrer to the complaint on the ground that the facts alleged did not constitute a cause of action and dismissed the complaint without day. Plaintiffs appealed to the Supreme Court.
The Supreme Court (Carson, J., for the Court) reviewed the complaint and incorporated exhibits and court records (including the two appealed causes). It considered (a) whether judges of superior/general jurisdiction are civilly liable for judicial acts done within their legal powers and jurisdiction...(Subscriber-Only)
Issues:
- Is Justice E. Finley Johnson civilly liable in damages for acts performed in the exercise of his judicial functions as an associate justice of the Supreme Court of the Philippine Islands?
- Do the facts pleaded in the complaint (read with the exhibits and court records incorporated therein) state a cause of action because the judgments complained of were erroneously entered?
- Do the allegations in the complaint sufficiently plead bad faith, malice or willful misconduct by Justice Johnson such that a civil action for damages lies?
- Was Justice Johnson’s provisional amendment of the memorandum order and his direction to suspend...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)