G.R. No. 173002 - Bautista vs. Ugst

The case originated after the acquittal of Sgt. Cesar Mallari in Criminal Case No. F-149450 for Slight Physical Injuries.
Complainant Erlinda Pabalan filed a letter-complaint on December 3, 1972, addressed to the Secretary of National Defense.
In her complaint, Pabalan charged respondent City Judge Donato M. Guevarra with having knowingly rendered an unjust judgment and/or acted with ignorance of the law or through inexcusable negligence.

The complaint was referred to the Secretary of Justice, and on December 21, 1972, the respondent was directed to submit his comment within seventy-two (72) hours upon receipt of the charges.
Judge Guevarra submitted his comment on January 12, 1973, in which he denied the allegations by citing portions of the transcript of stenographic notes from the proceedings.
The matter was subsequently reviewed by the Technical Staff of the Office of the Chief Justice.

The record included numerous transcript excerpts from the hearing of August 16, 1972.
Specific aspects of the proceedings that were highlighted include:

Alleged prevention of cross-examination of defense witness Pat. Gelvas by Judge Guevarra.
Contentions that the judge’s sustained objections during questioning were “nonsensical” and indicative of ignorance of the law.

Objections raised by defense counsel regarding the phrasing and content of the questions posed to witnesses, such as the improper injection of opinion (e.g., using words like “gladly” or “loaded question”).
The judge’s interventions, including sustaining and modifying questions while questioning the materiality and framing of certain inquiries.

The transcript showed that the judge’s actions appeared to follow standard courtroom procedure:

When objections were raised, the responses included queries about the relevance, materiality, and proper evaluation of the witness testimony.
The judge’s remarks emphasized that certain questions were designed to elicit conclusions or opinions that, by principle, should be rendered by the parties involved rather than the witness.

That Judge Guevarra prevented the private prosecutor from properly cross-examining a key witness.
That the judge demonstrated “sheer ignorance of the law” by sustaining what were considered inappropriate objections during the proceedings.
That the judge’s actions reflected an erroneous appraisal of the evidence which contributed to an unjust judgment.

Asserted that his actions were consistent with proper judicial procedure and that the allegations of misconduct were unfounded.
Emphasized that the risks of errors in evidence appraisal are inherent in judicial decision-making and do not automatically constitute grounds for administrative or civil liability.

Whether the complaint against Judge Guevarra alleging that he rendered an unjust judgment by obstructing proper cross-examination and sustaining improper objections is founded on solid factual basis.

Did the judge’s actions during the hearing—specifically regarding the questioning of witnesses, including objections to the phrasing and scope of questions—amount to a deliberate refusal to allow proper cross-examination?
Is there evidence that the judge’s evaluation of the evidence was so flawed as to be deemed “unjust” or contrary to law?

Whether a judicial officer may be held administratively or civilly liable for acts performed in the exercise of judicial functions even if errors in appraisal are alleged.

Does the principle of judicial immunity extend to protect the judge in this instance?
Can an error in evidence evaluation, if any, be equated with a deliberate, unjust decision warranting liability?