Facts:

The case involves a verified complaint filed by Adelpha E. Malabed against Judge Enrique C. Asis of the Regional Trial Court, Branch 16, Naval, Biliran, on February 23, 2006. The complaint alleges that Judge Asis violated Rule 1.02, Canon I of the Code of Judicial Conduct by exhibiting bias and partiality in Civil Case No. B-1016, which was entitled "Adelpha E. Malabed v. Spouses Ruben Cericos and Delia Cericos." The background of the case began when Malabed acquired a parcel of land from her brother, Conrado Estreller. After the acquisition, the spouses Cericos commenced construction of a house on the land. Malabed informed the Cericos of her intention to use the land and requested them to vacate. Following their refusal to leave, Malabed filed a civil case for ejectment and damages in the Municipal Circuit Trial Court (MCTC) of Kawayan-Almeria, which ruled in her favor on July 11, 1997. The Cericos appealed to the RTC, where Judge Asis affirmed the MCTC's deci...

Facts:

1. Acquisition of Land and Dispute:

   • Complainant Adelpha E. Malabed acquired a parcel of land from her brother, Conrado Estreller.
   • Defendants, Spouses Ruben and Delia Cericos, built a house on the land before the title was transferred to Malabed.
   • Malabed demanded the Spouses Cericos to vacate the land, but they refused, leading to a civil case for ejectment and damages filed by Malabed in the Municipal Circuit Trial Court (MCTC) of Kawayan-Almeria, Biliran, docketed as Civil Case No. 860.

2. MCTC Decision:

   • The MCTC ruled in favor of Malabed, ordering the Spouses Cericos to vacate the land, pay attorney’s fees, litigation expenses, and damages.
   • The Spouses Cericos appealed to the Regional Trial Court (RTC), Branch 16, Naval, Biliran, presided by respondent Judge Enrique C. Asis. The case was re-docketed as Civil Case No. B-1016.

3. RTC Decision and Subsequent Motions:

   • On January 25, 1999, Judge Asis affirmed the MCTC decision.
   • The Spouses Cericos filed a Motion for Reconsideration, which was denied on March 4, 1999.
   • A Writ of Execution was issued on May 3, 1999, leading to the padlocking of the Spouses Cericos' house and the delivery of possession to Malabed.

4. Petition for Relief from Judgment:

   • On May 12, 1999, the Spouses Cericos, represented by new counsel Atty. Meljohn de la Peña, filed a Petition for Relief from Judgment, alleging that Malabed failed to disclose a prior verbal agreement allowing them to build on the land.
   • Judge Asis granted the petition on August 12, 1999, ordering a new trial. Malabed’s Motion for Reconsideration was denied on December 20, 1999.

5. Court of Appeals (CA) Decision:

   • Malabed filed a petition for certiorari with the CA, which annulled Judge Asis’ Orders dated August 12, 1999, and December 20, 1999, ruling that the Petition for Relief was filed out of time and that the alleged fraud was intrinsic, not extrinsic.

6. Administrative Complaint:

   • Malabed filed an administrative complaint against Judge Asis, alleging bias and partiality in favor of the Spouses Cericos because their counsel, Atty. De la Peña, had represented Judge Asis in other administrative cases.
   • Judge Asis denied the allegations, stating that the administrative case where Atty. De la Peña represented him was filed after the issuance of the contested orders.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Bias and Partiality:

   • The Court held that mere suspicion of bias is insufficient to hold a judge administratively liable. Clear and convincing evidence is required, which was not sufficiently established in this case.
   • The fact that Atty. De la Peña represented Judge Asis in other administrative cases did not prove bias, as those cases were filed after the issuance of the contested orders.

2. Gross Ignorance of the Law or Procedure:

   • The CA found that the Petition for Relief was filed out of time, and Judge Asis erred in granting it. The Court emphasized that judges must be conversant with basic procedural rules, and failure to observe them constitutes gross ignorance of the law or procedure.
   • While the error may not have been tainted with bad faith, it was still a serious lapse warranting administrative sanction.

3. Judicial Immunity and Errors of Judgment:

   • The Court reiterated that judges are immune from administrative liability for errors of judgment unless there is evidence of bad faith, malice, or corrupt intent.
   • However, in this case, the procedural error was so elementary that it amounted to gross ignorance of the law, warranting a fine.

4. Prior Administrative Cases:

   • The Court considered Judge Asis’ prior administrative cases, which showed a pattern of misconduct. This influenced the imposition of a fine, as the Court sought to deter future lapses.