Case Digest: SANTIAGO III v. JUSTICE ENRIQUEZ, JR.

GENARO SANTIAGO III v. JUSTICE JUAN Q. ENRIQUEZ, JR.
579 SCRA 1 (2009)

Under the principle of “judicial immunity”, judges cannot be held criminally, civilly or administratively liable for an erroneous decision rendered in good faith.

The complainant Genaro Santiago III filed a Petition for Reconstitution of Lost/ Destroyed Original Certificate of Title No. 56, registered in the name of Pantaleona Santiago and Blas Fajardo. The Regional Trial Court of Quezon City granted the petition. The Republic of the Philippines, through the Office of the Solicitor General, appealed to the Supreme Court asking for its reversal.

The case was raffled to Justice Marlene Gonzales-Sison, Justice Vicente Veloso and herein respondent Justice Juan Enriquez. Justice Gonzales-Sison was the one who made the Report as the basis for the Division’s consultation and deliberation which upholds the decision made by the RTC of Quezon City. Justice Veloso concurred in the Report made. On the other hand, Justice Enriquez dissented to the Report and made his own Dissenting Opinion. Justice Enriquez requested for another two (2) Justices to form a Special Division, Justice Edgardo Cruz and Justice Lucas Bersamin were then included. After the deliberations, the Dissenting Opinion of Justice Enriquez became the majority opinion. The decision of the RTC of Quezon City was reversed by the decision made by the Special Division.

Complainant Santiago then filed an administrative complaint against Justice Enriquez on the ground of gross ignorance of the law, and gross incompetence in connection with his rendering of alleged unjust judgment in the case of Santiago. Justice Enriquez contends that it was a mere nuisance and that it was filed prematurely.

ISSUE:

Whether or not there is a valid ground for the filing of an administrative case against Justice Enriquez

HELD:

The Court has to be shown acts or conduct of the judge clearly indicative of the arbitrariness or prejudice before the latter can be branded the stigma of being biased and partial. Thus, unless he is shown to have acted in bad faith or with deliberate intent to do an injustice, not every error or mistake that a judge commits in the performance of his duties renders him liable.

The principle of ―judicial immunity‖ insulates judges, and even Justices of superior courts, from being held to account criminally, civilly or administratively for an erroneous decision rendered in good faith. To hold otherwise would render judicial office untenable. No one called upon to try the facts or interpret the law in the process of administering justice could be infallible in his judgment.

It bears particular stress in the present case that the filing of charges against a single member of a division of the appellate court is inappropriate. The Decision was not rendered by respondent in his individual capacity. It was a product of the consultations and deliberations by the Special Division of five.