A.M. No. RTJ-05-1935 - Suarez-De Leon vs. Estrella

Evelyn Suarez-De Leon, one of the plaintiffs in Civil Case No. 51203 (“Danilo Suarez, et al. vs. Valente Raymundo, et al.”), filed a sworn letter-complaint on June 17, 2000, with the Office of the Court Administrator (OCA) alleging serious misconduct and gross ignorance of the law by Judge Santiago G. Estrella, pairing judge of the Regional Trial Court (RTC) of Pasig City, Branch 67.
The underlying Civil Case No. 51203 sought the annulment of the judicial sale of several parcels of land and involved the determination of portions of an estate, specifically concerning the heirs of the decedent Marcelo Suarez.

The trial court initially dismissed Civil Case No. 51203 for failure to prosecute, only for the dismissal to be lifted upon the complainant’s motion for reconsideration.
Subsequently, the defendants appealed the trial court’s decision resulting in the Court of Appeals (CA) ordering the dismissal of the case on July 27, 1990.
The complainant escalated the matter to the Supreme Court, which, on September 4, 1992, reversed the CA decision and reinstated Civil Case No. 51203 for the specific purpose of determining the portions belonging to the petitioners and annulling the sale with respect to those portions.

On January 22, 1996, RTC Pasig City, Branch 67, then headed by Judge Apolinario B. Santos, issued an order enforcing the Supreme Court’s mandate by requiring petitioners to submit evidence showing settlement of the estate of Marcelo Suarez.
On January 11, 2000, Judge Santiago G. Estrella, serving as the pairing judge, issued an order dismissing Civil Case No. 51203. His dismissal relied on a precedent—“Heirs of Yaptinchay vs. Del Rosario”—which held that declarations of heirship should be pursued in a special proceeding rather than an ordinary civil action.

Complainant contended that by dismissing Civil Case No. 51203, Judge Estrella had disregarded the Supreme Court’s final decision in G.R. No. 94918, thus displaying evident bad faith, manifest partiality in favor of the defendants, and gross ignorance of the law.
The respondent judge defended his action by asserting that no trial on the merits took place and that evidence had not been presented to establish the complainants as the legitimate, compulsory heirs, arguing that such declaration of heirship should be conducted through a special proceeding.

An OCA report dated November 7, 2001, found no evidence to demonstrate that the dismissal was motivated by corruption or improper purposes; however, it noted that Judge Estrella erred in setting aside the final and executory Supreme Court judgment in G.R. No. 94918.
Subsequent resolutions from the Supreme Court in December 2001 and March 2003 directed the parties regarding manifesting willingness to submit to resolution and comply with directives, although the complainant failed to comply.
Finally, on May 16, 2005, the Court issued a resolution considering the matter for failure of the complainant to follow court directives, culminating in the administrative complaint against Judge Estrella.

Whether the dismissal of Civil Case No. 51203 by Judge Santiago G. Estrella was in contravention of the Supreme Court’s final decision in G.R. No. 94918.

The issue centers on whether the judge’s action of dismissing the case was an improper disregard for the mandated reinstatement provided by the Supreme Court.
It examines if his reliance on the ruling in “Heirs of Yaptinchay vs. Del Rosario” was misplaced given the controlling nature of the earlier Supreme Court decision.

Whether Judge Estrella’s conduct in dismissing the case demonstrates serious misconduct, manifest partiality, and gross ignorance of the law.

The issue requires analysis of whether the judge’s conduct, as alleged by the complainant, satisfies the elements of bad faith and incompetence in his judicial functions.
It also involves determining if his decision to dismiss the proceedings reflects a deliberate or negligent disregard for judicial directives.

Whether the administrative complaint against Judge Estrella is supported by sufficient evidence to warrant disciplinary action or separation from service.

The inquiry considers if the complainant has met the burden of proof required in administrative proceedings against a judicial officer.
It evaluates if the evidence presented corroborates the allegations of misconduct, partiality, and ignorance of the law.