Case Digest (A.M. No. RTJ-05-1905)
Facts:
Charito L. Planas v. Judge Ernesto A. Reyes, A.M. RTJ-05-1905 [OCA-IPI No. 03-1712-RTJ], February 23, 2005, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.Complainant Charito L. Planas, Executive Director of the Nayong Pilipino Foundation (NPF), filed an administrative complaint against Judge Ernesto A. Reyes, presiding judge of the Regional Trial Court (RTC), Branch III, Pasay City, alleging ignorance of the law, manifest bias and partiality, grave misconduct and inefficiency arising from his rulings in an unlawful detainer case originally decided by the Metropolitan Trial Court (MeTC), Pasay City, Branch 45.
The MeTC (Judge Zenaida G. Laguilles) rendered judgment on February 26, 2002 in favor of NPF ordering PVHI and persons claiming under it to vacate and pay arrears and rentals; PVHI and Jose Marcel Panlilio appealed. No supersedeas bond was posted in the trial court. The appeals were elevated to the RTC and raffled to Branch III (respondent judge). NPF moved for issuance of writ of execution on April 10, 2002; respondent denied the motion in an April 29, 2002 order, reasoning that once the case was perfected to the RTC the lower court could no longer require a supersedeas bond and that defendants had posted a supersedeas bond before the RTC.
NPF filed a second motion for issuance of writ of execution (manifestation that PVHI failed to deposit accrued and current rentals), which respondent again denied in an August 20, 2002 order. NPF filed a Motion for Reconsideration on September 18, 2002; respondent did not act on that motion but proceeded to resolve the appeal, issuing an RTC decision on November 29, 2002 that modified the MeTC judgment in several respects and directed the parties on options and payments.
NPF’s administrative complaint charged respondent with (a) improperly denying execution despite defendants’ failure to file sufficient supersedeas bond in the trial court; (b) approving the supersedeas bond without notice and despite lack of Panlilio’s signature; (c) denying execution despite defendants’ failure to deposit rentals; (d) denying execution despite alleged cancellation of the bond; and (e) deciding the appeal without resolving the motion for reconsideration and otherwise misconstruing the parties’ rights. Respondent answered that his acts were judicial in nature, that the filing of the supersedeas bond is not a condition to perfection of appeal, and that NPF had available judicial remedies it did not pursue.
The Office of the Court Administrator (OCA) evaluated the matter, concluded respondent erred in d...(Pro-only)
Issues:
- Is an administrative complaint the proper remedy to challenge the respondent judge’s interlocutory orders denying execution and related judicial acts when judicial remedies are available?
- Were the actions of respondent judge tantamount to manifest bias, gross ignorance of the law, bad faith, or other administrative offenses warranting discipline?
- Was the denial of the motions for execution and subsequent disposition of the appeal a ground fo...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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