A.M. No. RTJ-04-1888 - Maquiran vs. Grageda

Complainant Edgardo O. Maquiran filed an administrative complaint against Judge Jesus L. Grageda of the Regional Trial Court, Branch 4, Panabo City, Davao del Norte.
The complaint arose from matters pertaining to Civil Case No. 95-45, which involved more than 7,000 Filipino claimants and several U.S.-based multinational corporations (Shell Oil Co., Dow Chemical Company, Occidental Chemical Corporation, Standard Fruit Company, DOLE Fresh Fruit Company, Chiquita Brands, and Del Monte Fresh Produce).
The Filipino claimants, exposed to the chemical “dibromochloropropane” on banana plantations, had initially pursued mass tort and damages claims abroad. Cases were dismissed in U.S. courts based on forum non conveniens, prompting consolidation of actions domestically.

A global settlement had been reached through the Compromise Settlement, Indemnity, and Hold Harmless Agreements, leading to the filing of civil actions in the Philippines.
One of the civil cases, raffled as Civil Case No. 95-45, was assigned to Judge Grageda.
On December 20, 2002, Judge Grageda approved the settlement by issuing an Omnibus Order.
Plaintiffs moved to execute this order, and on April 15, 2003, the writ of execution was granted, being issued on April 23, 2003.
The writ of execution, however, was returned unsatisfied when defendant corporations argued that settlement obligations had been fulfilled.

Defendant corporations filed motions for reconsideration and quashal of the writ, asserting that no further execution was possible given the satisfaction of settlement terms.
On June 30, 2003, Judge Grageda issued an Order granting the reception of evidence in the United States at the expense of the defendants.
The Order also suspended further implementation of the writ of execution until the U.S. evidentiary proceedings were completed.
Subsequently, Judge Grageda submitted requests to the Office of the Court Administrator (OCA) for permission to be "on court duty" and for leave of absence to visit his daughter in New York, which dovetailed with his plan to conduct proceedings abroad.
On July 18, 2003, he supplemented his earlier order by outlining procedural details for the U.S. proceedings, including the roles of parties, members for document transmission, and the logistics of handling voluminous evidentiary materials.
From August 27 to September 29, 2003, while in the United States and even while on leave (originally granted solely to visit his daughter), Judge Grageda conducted judicial proceedings at the Philippine Consulate General Office in San Francisco, California, which included the authentication and examination of documents and the reception of evidence from a variety of witnesses and defendants.

Accused of ordering the stay of the writ of execution and directing his staff to travel abroad for further evidence reception without proper authorization.

Allegedly suspended the writ of execution after defendants purportedly offered him a free trip to the U.S. with accompanying benefits (free passport and visa services, round-trip tickets, hotel accommodations, food, and daily allowances).

Conducted judicial proceedings outside the territorial jurisdiction of the Philippine courts by holding court sessions in San Francisco without proper approval from the Supreme Court.

Charged with failing to exercise due diligence and caution in avoiding even the slightest legal infraction, particularly by accepting favors implicitly connected with his travel and conduct of court sessions abroad.

Alleged to have rendered a manifestly unjust judgment through orders that stayed the execution, purportedly to accommodate the additional evidentiary proceedings overseas.

The so-called “abuse of discretion” was based on his duty to ensure that the evidentiary record was complete before executing the judgment.
There was no direct bribery since the benefits (such as passport and visa) were obtained through normal governmental procedures, and the trip was to secure the truth regarding conflicting evidentiary claims.
The reception of evidence in the U.S. was meant to facilitate an accurate resolution of complex issues raised by the settlement agreements, falling under the expansive reading of Section 6, Rule 135 of the Rules of Court.

He argued that his actions, though unorthodox (i.e., conducting proceedings abroad), were driven by a good faith belief in his responsibility as the sole judge over a very difficult case, despite lacking express authority for such extraterritorial conduct.
His detailed explanations, including requests for travel and attempts to secure extensions for his leave of absence, were presented as mitigating circumstances, although procedural irregularities were nonetheless noted.

The Office of the Court Administrator (OCA) reviewed the judge’s letter requests, subsequent orders, motions, and the entire record of proceedings.
Memoranda by Deputy Court Administrator Christopher O. Lock recommended denial of the request to extend court duty coverage abroad for evidentiary purposes, highlighting that judicial power is confined to proper territorial boundaries.
The investigation found reasonable grounds to hold Judge Grageda administratively liable for conducting unauthorized judicial proceedings outside the jurisdiction of the Philippine courts.
Despite the judge’s good performance record in nearly nine years of service, his unauthorized actions and deviations from prescribed procedural norms were deemed sufficient to warrant administrative sanctions.

Whether Judge Grageda abused his judicial discretion by issuing an Order staying the writ of execution and authorizing evidentiary proceedings in the United States without proper judicial or administrative approval.
Whether the alleged acceptance of benefits (including a free trip and other travel-related privileges) by the judge constitutes direct bribery.
Whether conducting judicial proceedings at the Philippine Consulate General Office in San Francisco violates the territorial limits imposed by B.P. Blg. 129.
Whether Judge Grageda’s conduct constitutes a violation of the Canons of Judicial Ethics, particularly the requirement for judges to avoid any semblance of impropriety or acceptance of favors from parties involved in cases before them.
Whether the issuance of an Order under Article 206 of the Revised Penal Code amounts to knowingly rendering a manifestly unjust judgment.
Whether the good faith defense invoked by the judge is sufficient to absolve him of administrative liability despite procedural and jurisdictional missteps.