G.R. No. 254328 - Baysa vs. Santos

Case Summary (G.R. No. 254328)

Background of the Case

On June 30, 2003, Baysa rendered a decision in favor of the tenants Perfecto Cabral and Loreda G. Vda. de Almario against the Spouses Constantino and Zenaida Pascual in a DARAB case involving agrarian land disputes. The decision became final and executory on August 14, 2008, leading to the issuance of a writ of execution against the Pascuals on September 10, 2009. Following this, the tenants filed a motion for a writ of demolition, which notably did not specify the nature or location of structures to be demolished.

Involvement of Respondent Santos and Motion for Injunctive Relief

Santos, with no participation in the original DARAB proceedings, was nevertheless furnished copies of related motions and orders. She discovered that part of the property subject to demolition was her own. She filed for injunctive relief before the Regional Trial Court (RTC) to stop the demolition, asserting that she was not made a party to the case and that the DARAB lacked jurisdiction over her property. She also moved for disciplinary action against the sheriff executing the writ and sought to restrain the tenants from disturbing her property rights. Baysa denied this motion and subsequent reconsideration.

Administrative Charges and Defense

Santos filed an administrative complaint against Baysa before the Office of the Ombudsman (OMB), charging him with unjust judgment ("maling hatol") and erroneous issuance of the writ ("maling akala"). Baysa defended himself by arguing that Santos’s title was derived from the Spouses Pascual, thereby binding her to the decision. He maintained that Santos failed to substantiate her claim to the property during the execution proceedings. Baysa also asserted he afforded Santos due process as she actively participated in the hearings before his denial of her motions.

Determination by the Office of the Ombudsman

On May 28, 2015, the OMB found Baysa guilty of Simple Misconduct and suspended him for three months without pay. The OMB concluded that Baysa exceeded his authority when ordering the demolition of Santos’s property without due process and noted his disregard for applicable laws as indicative of lack of professionalism and competence.

Proceedings Before the Court of Appeals

Baysa petitioned for review, contending that: (1) he did not violate laws or jurisprudence; (2) the OMB usurped the judicial functions of the DARAB and the Court of Appeals; (3) Santos failed to prove misconduct by substantial evidence; (4) the OMB erred in ignoring his length of service and (5) the OMB failed to cite the specific Code of Conduct violation.

The Office of the Solicitor General (OSG) supported the OMB’s findings, citing substantial evidence, including Baysa’s own admission that Santos was not a party in the proceeding.

Decision of the Court of Appeals

On January 14, 2020, the Court of Appeals affirmed the OMB’s ruling. It held that, while judgments bind heirs or successors-in-interest, Baysa erred in considering Santos a successor-in-interest of the Spouses Pascual. The appellate court found that Santos was never impleaded as a party, and thus the writ of demolition and related orders were executed in violation of her right to due process. It outlined that:

Santos was not mentioned or made a respondent in original or subsequent DARAB filings;
She was merely furnished copies of motions without explanation;
Baysa failed to hold a hearing on her motion for relief;
The tenants’ complaint that her property was part of the land they claimed was unsupported by evidence;
Baysa disregarded evidence showing Santos’s property was distinct from the land subject to litigation; and
These actions amounted to a breach of due process constituting simple misconduct.

The Court of Appeals denied reconsideration on October 26, 2020.

Issues Raised in the Petition for Review to the Supreme Court

Baysa sought the Supreme Court’s intervention to reverse the Court of Appeals, reiterating that he afforded Santos due process, that his orders had proper legal bases, and that his execution did not exceed the scope of his jurisdiction. He additionally contended that the caretaker of Santos’s property properly received service of the writ of execution.

Supreme Court’s Analysis and Ruling

The Supreme Court reversed the Court of Appeals and OMB decisions. It emphasized the principle that disciplinary proceedings against judges or quasi-judicial officers are not substitutes for judicial remedies. Exhaustion of judicial remedies and final judgments are prerequisites before administrative sanctions may be imposed. This is to safeguard quasi-judicial officers from administrative sanctions arising from their judicial or quasi-judicial acts unless there is bad faith or gross abuse of discretion.

Baysa’s acts pertained to his quasi-judicial functions as DARAB Provincial Adjudicator. Santos had already availed herself of judicial remedies by filing a petition for certiorari before the Court of Appeals, which ruled against the orders issued by Baysa. However, there was n

Case Syllabus (G.R. No. 254328)

Case Background and Parties Involved

Petitioner Andrew N. Baysa served as the Provincial Adjudicator of the Office of the Provincial Agrarian Reform Adjudicator, Department of Agrarian Reform Adjudication Board (DARAB), Malolos City.
Respondent Marietta V. Santos filed charges against Baysa for unjust judgment ("maling hatol") and erroneous issuance of a writ of demolition ("maling akala") concerning her property.
The case stems from DARAB Case No. R-03-02-990799, where Baysa ruled in favor of Perfecto Cabral and Loreda G. Vda. de Almario, tenants against Spouses Constantino Pascual and Zenaida Pascual.
Baysa’s decision was final and executory as of August 14, 2008, and led to issuance of a writ of execution on September 10, 2009 and subsequent motion for a writ of demolition filed by the tenants, who also sought demolition of structures on the land.
Santos was not made a party to the DARAB proceedings yet received multiple pleadings and notices concerning the case, despite having no participation or being impleaded.
Santos’ building, located on her distinct landholding, was nonetheless included in the demolition order, leading her to seek injunctive relief on grounds of wrongful inclusion and violation of due process.

Factual and Procedural History

Santos received various orders and notices about the case, including the motion for issuance of the writ of demolition, without explanation as to why she was served although not a party.
Santos filed motions opposing the demolition and sought disciplinary action against the Sheriff who attempted to serve the writ on her property.
Baysa denied Santos' motions by orders dated July 22, 2010, and February 22, 2011, which prompted her to file an administrative complaint for misconduct.
Bambsa, in his defense, argued Santos was bound by the decision because her property’s title was derived from Spouses Pascual, the named parties in the case, positing there was privity.
The Office of the Ombudsman (OMB), however, found Baysa guilty of simple misconduct, suspending him for three months without pay, citing disregard of applicable laws and due process.
Baysa appealed to the Court of Appeals, asserting lack of substantial evidence, improper consideration of his length of service as mitigating, and failure of the OMB to identify specific code violations.
The Court of Appeals affirmed Baysa's liability, emphasizing failure to afford Santos due process and improp