A.M. No. 227-RTJ – 145 SCRA 1 – Legal Ethics – Judicial Ethics – Liability of Judges for Erroneous Decisions
There are two administrative cases against Judge Ildefonso Bleza here.
Case 1
In 1981, a shooting incident in a cockpit occurred where Gregorio Abad, a colonel escaped death. In that incident, Abad had an argument with one Potenciano Ponce and the latter’s bodyguard, Francisco Sabater Jr. Sabater shot Abad and due to medical intervention, Abad survived. Abad filed two separate criminal cases against Ponce and Sabater. Ponce was acquitted due to insufficiency of evidence (because there were conflicting testimonies) while Sabater was found guilty of frustrated homicide but with mitigating circumstances of voluntary surrender and lack of intent to kill.
Abad, not satisfied with Bleza’s decisions filed an administrative case against Bleza,
Case 2
Pacifico Ocampo was an employee of the Manila International Airport Authority. He filed an administrative case against one Ricardo Ortiz.
After that, Ocampo alleged that Crisanto Cruz (perhaps a friend of Ortiz? – not mentioned in the case), tried to persuade Ocampo not to continue with the administrative case against Ortiz. Ocampo did not accede so allegedly, Cruz filed a separate administrative complaint against Ocampo. In turn, Ocampo filed a civil case against Cruz before Judge Bleza. Ocampo alleged that the administrative case against him was baseless and the same made him suffer embarrassment, mental shock, anxieties, sleepless nights, and loss of appetite.
Ocampo won and Bleza ordered Cruz to pay for damages. Cruz filed an administrative case against Bleza for allegedly knowingly rendering a wrongful decision as Cruz averred that the administrative case was based on Ocampo’s absenteeism, inefficiency and tardiness which were all on record and same were presented as evidence which were even (allegedly) uncontroverted.
ISSUE: Whether or not Bleza should be disciplined.
HELD: No (in both cases). In the first case, Bleza erred in appreciating the mitigating circumstance of lack of intent to kill in favor of Sabater – but such error does not hold him administratively liable.
In Criminal Law, in cases of frustrated homicide there is inherently an intention to kill for if otherwise, it would have been a case of physical injuries. Bleza found Sabater guilty of frustrated homicide hence it is error for him to appreciate lack of intention to kill as a mitigating circumstance.
But as a matter of public policy, in the absence of fraud, dishonesty or corruption, the acts of a judge in his judicial capacity are not subject to disciplinary action, even though such acts are erroneous. Even on the assumption that the judicial officer has erred in the appraisal of the evidence, he cannot be held administratively or civilly liable for his judicial action. A judicial officer cannot be called to account in a civil action for acts done by him in the exercise of his judicial function, however erroneous. Not every error or mistake of a judge in the performance of his duties makes him liable therefor. To hold a judge administratively accountable for every erroneous ruling or decision he renders, assuming that he has erred, would be nothing short of harassment and would make his position unbearable.
In the second case, the Supreme Court took notice of the fact that it is on appeal before the Court of Appeals hence it is premature to decide upon it. Only after the appellate court holds in a final judgment that a trial judge’s alleged errors were committed deliberately and in bad faith may a charge of knowingly rendering an unjust decision be leveled against him.
