Facts:

The case Emilia Alzua and Ignacio Arnalot vs. E. Finley Johnson (G.R. No. 7317) arose from an appeal by the plaintiffs, Emilia Alzua and Ignacio Arnalot, against the demurrer dismissal issued by the Court of First Instance of Manila. The incident dates back to actions that took place in 1905 and 1907 in the city of Manila. The plaintiffs accused E. Finley Johnson, an associate justice of the Supreme Court of the Philippine Islands, of engaging in misconduct by deliberately misrepresenting facts in a judicial opinion that allegedly induced the court to enter an erroneous judgment against Alzua. Alzua sought damages amounting to approximately PHP 65,000, which included losses from selling property at a sacrifice to satisfy a judgment she claimed was wrongfully entered. The crux of the complaint was that the judicial opinions written by Johnson contained "false and misleading statements of the facts," which led to a judgment a

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Facts:

Parties and Allegations

• The plaintiffs, Emilia Alzua and Ignacio Arnalot, brought an action against E. Finley Johnson, an associate justice of the Supreme Court of the Philippine Islands, alleging that he engaged in judicial misconduct.
• The complaint alleges that the defendant, while acting in his judicial capacity, materially altered official records and misrepresented facts in the course of resolving appeals, thereby causing significant damages to the plaintiffs.

Underlying Proceedings and Judicial Actions

• The controversy originates from two separate causes:
• Cause No. 4017 – An injunction action involving a levy on partnership property (specifically, related to stores owned by parties in a partnership) where the Soler family (sons of Visitacion Martinez) asserted claims that conflicted with those of plaintiff Alzua.
• Cause No. 5719 – An action related to an indemnity bond executed by plaintiff Alzua in favor of the sheriff, which purportedly led to the wrongful execution of a judgment.
• The complaint incorporates extensive extracts of the official pleadings and exhibits (Exhibits A–F) to support allegations that:
• The written opinions and orders, including a memorandum order prepared on March 27, 1907, were tainted by intentional modifications.
• On or about April 8, 1907, while the court was in vacation mode, the defendant unilaterally struck out the word “affirmed” and replaced it with “reversed” in the official record, thereby affecting the execution and finality of the underlying judgments.

Procedural History and Administrative Actions

• The original Supreme Court decision rendered on March 27, 1907, affirmed the judgment of the lower court; however, the defendant, acting as vacation justice, later altered its text.
• Defendant’s act of amending the memorandum order was accompanied by a directive to the clerk to suspend the execution of the order until further instructions, and the subsequent ratification of the amendment was later recorded by the court.
• The plaintiffs claim that these actions led to financial harm:
• They were forced to pay or execute a judgment amounting to sums that ultimately compelled them to sell valuable real estate (notably, an interest in a hotel) at a significant sacrifice.
• The alleged damages include actual, special, and punitive components amounting to substantial monetary losses.

Statutory and Evidentiary Context

• The complaint emphasizes that the defendant’s actions were performed during his designated vacation duty under provisions of Acts No. 136 and No. 867, as well as consistent with the rules governing interlocutory jurisdiction.
• The record incorporates official administrative orders, a copy of the complaint with its attached exhibits, and references to the pertinent provisions of both Philippine and imported Anglo‐American legal principles, illustrating the complexity and interrelation of the underlying disputes.

Issue:

Liability and Judicial Immunity

• Whether a judicial officer who acts within the scope of his judicial functions and legal authority can be held civilly liable for errors—even if those actions later cause damages.
• Whether the defendant’s conduct in amending the record and instructing the clerk, as alleged by the plaintiffs, constituted wrongful misconduct that would overcome judicial immunity.

Sufficiency of the Pleading

• Whether the facts alleged in the complaint, including charges of malice, bad faith, and improper conduct, are sufficiently concrete and detailed to sustain a cause of action.
• Whether the allegations, although acknowledging that the underlying facts may be true, are merely legal conclusions lacking the requisite factual underpinning.

Properness of Judicial and Administrative Procedures

• Whether the defendant’s unilateral amendment of the memorandum order without consulting the other justices (while on vacation duty) was within his legal authority.
• Whether the procedural handling—including the suspension of judgment entry and later ratification by the court—compromises the integrity of the judicial process or improperly prejudices the rights of the plaintiffs.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)