Title
Barroso vs. Arche
Case
Adm. Case No. 216-CFI
Decision Date
Sep 30, 1975
Retired stenographer filed an admin complaint against Judge Arche over a retirement benefits ruling; SC dismissed it as premature and unmeritorious.
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Case Summary (Adm. Case No. 216-CFI)

Background of the Case

  • Complainant Nonato Barroso, a retired stenographer, filed an administrative complaint against District Judge Andres P. Arche after the judge dismissed Barroso's case against the Government Service Insurance System (GSIS) regarding underpayment of retirement benefits.
  • Barroso's appeal against the dismissal was pending when he filed the administrative complaint, which alleged dishonesty, oppression, incompetence, inefficiency, and neglect of duty against the respondent judge.

Investigation Findings

  • The investigating Justice, Sixto Domondon, noted that the issues raised in Barroso's administrative complaint mirrored those in his pending appeal, making it inappropriate to rule on their correctness while the appeal was sub judice.
  • The investigation revealed no significant evidence of bias or malice on the part of Judge Arche, and the claim that the judge delayed the decision beyond 90 days was found to be factually incorrect.

Conclusion of the Investigation

  • Justice Domondon concluded that the administrative complaint was premature and prima facie unmeritorious, as it was based on the same issues that were already under appeal.
  • The investigating Justice emphasized that the judge's decision was based on a thorough appreciation of the evidence and upheld the GSIS's standard of computation for retirement benefits.

Supreme Court's Ruling

  • The Supreme Court ruled that the administrative complaint was not only premature but also improper, suggesting it was filed with malicious intent to harass the respondent judge.
  • The Court reiterated that a losing party must await the outcome of their appeal before filing an administrative complaint against a judge, unless there is clear evidence of malice or wrongful conduct.

Legal Principles Established

  • Judges cannot be held administratively liable for decisions made in good faith, even if those decisions are later found to be erroneous by an appellate court.
  • The appropriate remedy for a litigant dissa...continue reading

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