Case Summary (A.M. No. CA-13-51-J)
Procedural History and Initial Awards
On December 19, 2007, the Labor Arbiter granted death benefits and monetary claims to the heirs of Marlon Fabiana as follows: USD 82,500.00 for Merlita B. Fabiana, USD 16,500.00 to their child Jomari Paul B. Fabiana, salary differentials, sickness benefits, overtime pay, actual damages, moral damages of P100,000.00, exemplary damages of P1,000,000.00, and attorney's fees of 10% of the total award.
On December 10, 2008, the National Labor Relations Commission (NLRC) partially modified the award by reducing moral and exemplary damages to P50,000.00 each but affirmed the other awards.
Separate Petitions Filed to the Court of Appeals
Two separate petitions for certiorari were filed before the CA challenging different aspects of the NLRC decisions:
First Petition (C.A.-G.R. SP No. 109382): Filed by heirs of Marlon Fabiana, contesting NLRC jurisdiction to entertain Magsaysay’s appeal and seeking reinstatement of full moral and exemplary damages.
Second Petition (C.A.-G.R. SP No. 109699): Filed by Magsaysay Maritime and others, challenging the monetary awards granted to Fabiana’s heirs, asserting the cause of death was non-work related and outside contractual obligations.
CA Decision on the First Petition and Subsequent Motions
On September 29, 2009, the CA First Division partly granted the first petition, affirming the NLRC’s decision with modifications on interest rates and rejecting the motions for preliminary injunction and reconsideration filed thereafter. Magsaysay Maritime filed a motion for clarification, to which the CA responded on November 26, 2009, explaining the partial grant of the petition.
The heirs of Fabiana then filed a petition for review on certiorari to the Supreme Court, which, on January 13, 2010, denied the petition, affirming that the CA did not commit reversible errors, and the awards were supported by substantial evidence and correct application of law.
Motion to Dismiss the Second Petition and CA’s June 4, 2010 Resolution
The heirs of Fabiana filed a motion to dismiss the second CA petition on grounds of mootness following the first petition's resolution. However, on June 4, 2010, the CA First Division denied the motion to dismiss, explaining that the two petitions raised distinct issues: the first on jurisdiction and damages reduction, the second on the propriety of monetary awards. The division emphasized its prerogative to pass upon the second petition as it raised broader questions on death benefits and related claims.
Final Resolution of the Second Petition by the CA
On September 16, 2011, the CA Sixth Division dismissed the second petition, ruling there was no grave abuse of discretion by the NLRC in awarding the monetary claims.
Administrative Complaint Against CA Justices
Merlita B. Fabiana filed an administrative complaint against the three CA Justices involved in the denial of the motion to dismiss the second petition, accusing them of willfully disobeying the Supreme Court’s final resolution of January 13, 2010.
Court’s Analysis on the Administrative Complaint
The Supreme Court found the complaint to lack merit. It emphasized that the burden of proving willful disobedience lies with the complainant and must be substantiated by substantial evidence. The Court noted the first petition addressed NLRC jurisdiction and damages reduction, while the second petition tackled the monetary awards' propriety, thus not divesting the CA First Division of jurisdiction over the latter petition. The Justices’ issuance of a resolution answering the motion to dismiss was within their judicial discretion.
The Court stressed that the appropriate recourse against decisions of courts is to file judicial remedies such as motions for correction and appeals, not administrative complaints. It reiterated the principle that disciplinary or criminal actions against judges or justices are not substitutes for appeal or other judicial remedies. Such actions should be reserved for gross, deliberate, or malicious errors, violations of propriety, or conduct prejudicial to the administration of justice.
Legal Principles on Administrative Complaints Against Judges and Justices
The Court cited precedents that prohibit administrative or criminal prosecution as a substitute for judicial review, emphasizing the separation of powers and finality of court decisions. They reasoned that erroneous judicial rulings do not per se constitute administrative offenses unless marked by bad faith or gross negligence. Protecting judges and justices from baseless charges preserves judicial independence and prevents harassment.
Observations on Failure to Consolidate Related Petitions
The Court noted that the dispute could have been simplified had the CA exercised proper procedural discipline in consolidating related petitions pursuant to Section 3(a), Rule III of the 2009 Internal Rules of the Court of Appeals, which mandates consolidation of related cases to avoid inconsistent rulings and promote judicial economy.
The heirs of Fabiana had requested consolidation, but the CA initially did not act on this, causing unnecessary duplicative proceedings. The Court underscored that while consolidation is discretionary at the trial level for efficiency, it should be mandatory at appellate le
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Case Syllabus (A.M. No. CA-13-51-J)
Background and Nature of the Case
- This is an administrative matter originating from a claim for death benefits filed by the heirs of the late Marlon Fabiana against Magsaysay Maritime Corporation, its manning agent, and its principal, Air Sea Holiday GMBH-Stable Organizations Italia.
- Complainant Merlita B. Fabiana, the deceased’s surviving spouse, lodged a complaint against the Court of Appeals (CA) Justices Andres B. Reyes, Jr., Isaias P. Dicdican, and Stephen C. Cruz for allegedly defying the Supreme Court’s final resolution dated January 13, 2010, in G.R. No. 189726, which affirmed claims for death benefits and other monetary claims against the Maritime Company.
- The contention revolves mainly around the refusal of the CA First Division to dismiss or consolidate certain petitions related to the case despite the Supreme Court’s resolution, which complainant claimed they violated willfully.
Procedural History and Relevant Antecedents
- On December 19, 2007, the Labor Arbiter granted multiple claims in favor of the heirs of Fabiana, including US $82,500 death benefits to Merlita B. Fabiana, and various other monetary claims covering salary differentials, sick benefits, actual and moral damages, exemplary damages, and attorney’s fees.
- The National Labor Relations Commission (NLRC) modified the award, mainly reducing moral and exemplary damages but affirmed the rest on December 10, 2008.
- Two separate petitions for certiorari were filed to the CA:
- C.A.-G.R. SP No. 109382 by the heirs of Fabiana attacking the NLRC’s jurisdiction and reduction of damages;
- C.A.-G.R. SP No. 109699 by Magsaysay Maritime Corporation and its principal contesting the monetary awards.
- The CA First Division rendered a decision on September 29, 2009, on the first petition, partly granting and modifying the award, including imposing interest on monetary awards.
- A motion for clarification filed by Magsaysay was responded to by the CA on November 26, 2009.
- Heirs of Fabiana’s motion for reconsideration was denied, prompting their appeal to the Supreme Court, which denied the petition on January 13, 2010.
- Meanwhile, the heirs of Fabiana moved to dismiss the second petition (by respondents) as moot; the CA First Division denied the motion on June 4, 2010, refusing to consider the second petition moot.
- On September 16, 2011, the CA Sixth Division dismissed the second petition for lack of grave abuse of discretion by the NLRC.
Issues Raised by Complainant and Grounds of Administrative Complaint
- Complainant Merlita B. Fabiana accused the CA Justices from the First Division of willfully disobeying the Supreme Court’s 2010 resolution by entertaining and deciding the second petition despite its supposed mootness following the first petition’s resolution.
- The allegation of “willful disobedience” was lodged as an administrative complaint against the said Justices