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
Case Syllabus (Adm. Case No. 216-CFI)
Case Overview
- This case is an administrative complaint filed by Nonato Barroso against District Judge Andres P. Arche, stemming from an adverse decision rendered by the judge in a personal case involving Barroso’s retirement benefits.
- The complaint was filed on March 13, 1973, with the President of the Philippines and was subsequently referred to the Court through the Secretary of Justice on May 24, 1973.
- The administrative complaint was investigated by Justice Sixto Domondon of the Court of Appeals, who submitted a report on July 24, 1975.
Background of the Complaint
- Nonato Barroso, a retired former stenographer, filed the complaint following Judge Arche's decision on January 4, 1972, which dismissed Barroso's claim against the Government Service Insurance System (GSIS) for underpayment of retirement benefits.
- Barroso sought to recover P38,874.00 based on his own computation, while the GSIS had paid him P22,590.00 based on their standard computations.
- Barroso accused Judge Arche of dishonesty, oppression, incompetence, and inefficiency for not upholding his interpretation of the retirement law.
Investigation Findings
- Justice Domondon noted that the complaint was a direct result of the adverse decision in Barros...continue reading