Case Summary (A.M. No. CA-01-10-P)
Allegations Against the Respondent
Gonzales accused Judge Bersamin of grave misconduct, which includes the knowingly rendering of an unjust judgment and the issuing of unjust interlocutory orders. Additional charges involve his malicious refusal to recognize Gonzales as an indispensable party in the ongoing litigation and negligence in duties regarding Civil Case No. Q-94-21444. Gonzales argues that Judge Bersamin's decisions favored the Chans while disregarding her rights over the property subject to levy.
Background of the Case
The genesis of the case dates back to Criminal Case No. 1565-M-88, wherein the accused were ordered to pay Gonzales and her husband P600,000.00. In another case involving the same parties, they were awarded P3,700,000.00. The property at the heart of the dispute, under Transfer Certificate of Title (TCT) No. 319410, had notices of levy recorded against it for Gonzales' claims but was mired in a reconstitution process that complicated ownership assertions.
Sequence of Events Leading to Complaint
On August 23, 1994, the Chans filed for cancellation of the notices of levy, contending they were the rightful owners of the property due to a prior deed of absolute sale with the Cruz spouses. Complainant Gonzales's notices were carried over to the new title (TCT No. 50572) issued to the Chans, despite her claims being earlier in time. The judge expedited his decision, ordering the cancellation of the levy notices with potentially inadequate regard for Gonzales's rights.
Respondent's Defense
Judge Bersamin defended his actions, arguing that there was no need to notify Gonzales because she was not a party in the case. He claimed that any duty to inform her rested with the Register of Deeds rather than the court. He further denied allegations of haste or partiality, asserting that the previous registrars had ample opportunity to contest the action.
Findings of the Office of the Court Administrator
The Office of the Court Administrator recommended the dismissal of Gonzales' complaint, citing that she did not seek to intervene in the case and that her claims came after the prior deed of sale. It emphasized the lack of evidence demonstrating favoritism by Judge Bersamin towards the Chans. The memorandum pointed out that the judge had no obligation to give notice to Gonzales regarding the cancellation since she was a later registrant.
Conclusion of the Case Analysis
The court concluded
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Case Background
- Veronica Gonzales filed an administrative complaint against Judge Lucas P. Bersamin of the Regional Trial Court, Quezon City, for grave misconduct, unjust judgments, and dereliction of duty.
- The complaint arose from Civil Case No. Q-94-21444 involving spouses Gina Chan and Salvador Chan, who were contesting the validity of notices of levy on a property owned by Zoilo Cruz and Rosalinda Aldeguer Cruz.
- In prior cases, the accused had been ordered to pay damages to Veronica and Danilo Gonzales, leading to the issuance of notices of levy against the accused's property.
Relevant Cases and Transactions
- Criminal Case No. 1565-M-88: The accused were ordered to pay P600,000 to the Gonzales couple.
- Civil Case No. Q-91-10081: The accused were ordered to pay P3,700,000 to the Gonzales couple.
- Writ of Preliminary Attachment: Issued against the real property of the accused, leading to provisional notices of levy.
Procedural Developments
- The notices of levy were entered provisionally due to the pending reconstitution of the Certificate of Title (CTC) No. 319410.
- On December 3, 1991, the CTC was reconstituted, and a new title (TCT No. RT-48658) was issued to the spouses Cruz.
- The Chan spouses filed Civil Case No. Q-94-21444 against the Register of Deeds for the cancellation of their notices of levy, claiming ownership due to a prior deed of sale.
Allegations Against Respondent Judge
- Grave Misconduct: Complainant accused