Case Digest (A.M. No. CA-09-47-J)
Facts:
Genaro Santiago III v. Justice Juan Q. Enriquez, Jr., A.M. No. CA-09-47-J [Formerly A.M. OCA IPI No. 08-121-CA-J], January 25, 2010, Supreme Court En Banc, Carpio Morales, J., writing for the Court.
Complainant Genaro Santiago III filed a petition before the Regional Trial Court (RTC), Branch 220, Quezon City, for reconstitution of Lost/Destroyed Original Certificate of Title No. 56 (registered in the names of Pantaleona Santiago and Blas Fajardo). By Decision dated September 2, 2004, the RTC granted the petition. The Republic of the Philippines, through the Office of the Solicitor General, appealed to the Court of Appeals where the case was docketed as CA-GR CV No. 84167.
The case was raffled to Justice Marlene Gonzales‑Sison as ponente of the Thirteenth Division, of which respondent Justice Juan Q. Enriquez, Jr. was the Chairperson and Justice Vicente S.E. Veloso was the other member. Justice Gonzales‑Sison filed a Report on July 11, 2007. By letter dated July 18, 2007, Justice Enriquez expressed his dissent from the Report; Justice Veloso originally concurred with the Report but later asked that Justice Gonzales‑Sison revisit Enriquez’s dissent. On August 23, 2007 Justice Enriquez requested the Court of Appeals Raffle Committee to constitute a Special Division of five; the Raffle Committee, by Special Order dated August 24, 2007, designated Justices Edgardo P. Cruz and Lucas P. Bersamin as additional members.
After internal voting, Justice Enriquez’s Dissenting Opinion drew the concurrence of Justice Veloso and Justice Cruz, thereby becoming the majority opinion of the Special Division; Justice Gonzales‑Sison’s Report (with Justice Bersamin concurring) became the Dissenting Opinion. The Special Division’s Decision reversed and set aside the RTC decision. Complainant filed a Motion for Reconsideration (received by the CA on December 20, 2007).
Complainant filed an administrative complaint against Justice Enriquez (verified complaint dated December 27, 2007) alleging gross ignorance of the law and gross incompetence for allegedly twisting the law and jurisprudence to grant the appeal despite overwhelming evidence favoring complainant. Complainant also filed, on January 9, 2008, a motion for disqualification/inhibition of Justice Enriquez under Paragraph 2, Section 1, Rule 137; the Court of Appeals denied that motion by Resolution of April 20, 2008.
Pursuant to this Court’s directive, Justice Enriquez filed a Comment characterizing the administrative complaint as a nuisance and a tactic to harass him into inhibiting from the pending case; he argued the complaint was premature because motion for reconsideration was still pending, that the Decision was the product of a collegial body not his individual act, and that mere error in legal reasoning or appreciation of evidence does not ground administrative liability. Complainant filed a Reply...(Pro-only)
Issues:
- Was the filing of an administrative complaint against Justice Juan Q. Enriquez, Jr. proper and timely while judicial remedies (motion for reconsideration) remained available?
- Did Justice Enriquez’s participation in the Special Division’s Decision, including alleged erroneous appreciation of evidence and reliance on inapplicable authority, constitute administrative offenses such as gross ignorance of the law or gross incomp...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)