Administrative complaints are not the appropriate remedy for alleged errors committed by a quasi-judicial officer in the exercise of their adjudicative functions where judicial remedies exist and are available; administrative liability for such acts requires clear proof of bad faith, premeditation, obstinacy, or intentional wrongdoing, which was not established in this case.

The case originated from DARAB Case No. R-03-02-990799, where petitioner Baysa, as PARAD, rendered a decision in favor of tenants Cabral and Vda. de Almario against Spouses Pascual. This decision became final and executory. During the execution stage, a writ of demolition was sought, and respondent Santos, who claimed ownership of an adjoining property allegedly affected by the demolition, became involved despite not being an original party. Santos alleged her property was erroneously included and that she was denied due process.

• Petitioner Andrew N. Baysa was the Provincial Adjudicator of the DARAB, Malolos City.
• On June 30, 2003, Baysa rendered a decision in DARAB Case No. R-03-02-990799 in favor of tenants Cabral and Vda. de Almario against Spouses Constantino Pascual and Zenaida Pascual, which became final and executory on August 14, 2008.
• A writ of execution was issued on September 10, 2009, followed by a motion for a writ of demolition by Cabral and Vda. de Almario, which did not specify the location or nature of structures to be demolished.
• Respondent Marietta Santos, though not a party to the DARAB case, was furnished a copy of the motion for writ of demolition.
• Santos discovered that one of her buildings on her own parcel of land was among the properties sought to be demolished and sought injunctive relief from the RTC.
• Santos filed a motion before the DARAB (presided by Baysa) on May 7, 2010, asserting no jurisdiction over her person as she was not a party and that her property was distinct, and manifested her pending RTC action.
• Baysa denied Santos' motion on July 22, 2010, and her motion for reconsideration on February 22, 2011.
• Santos filed an administrative complaint with the Ombudsman against Baysa for unjust judgment and erroneous issuance of a writ of demolition.
• The Ombudsman found Baysa guilty of Simple Misconduct for going beyond his authority in ordering demolition of Santos' property without due process.
• The Court of Appeals affirmed the Ombudsman's decision, finding Baysa erred in considering Santos a successor-in-interest of Spouses Pascual and violated her right to due process.
• Santos had previously filed a petition for certiorari (C.A. G.R. S.P. No. 118531) before the Court of Appeals, successfully assailing Baysa's Orders of July 22, 2010, and February 22, 2011, where the CA noted Santos should have been impleaded.

• Baysa argued he did not disregard applicable laws and jurisprudence in issuing the assailed orders.
• Baysa contended that the OMB erroneously passed upon the merits of his quasi-judicial issuances, a matter for the Court of Appeals' review jurisdiction.
• Baysa claimed Santos failed to prove his liability for misconduct by substantial evidence.
• Baysa asserted that Santos was not deprived of procedural due process as she was afforded an opportunity to be heard.
• Baysa maintained that his orders denying Santos' motion had factual and legal bases, and he did not go beyond the scope of the final and executory decision.
• Baysa stated that Santos' caretaker, an actual occupant, received the writ of execution on her behalf.

• Santos charged Baysa with unjust judgment (maling hatol) and erroneous issuance of a Writ of Demolition on her property (maling akala).
• Santos alleged that Baysa, as PARAD, ordered the demolition of her property despite her not being a party to the original DARAB case, thus violating her right to due process.
• Santos insisted that the DARAB had no jurisdiction over her person or her property, which was distinct from the property subject of the DARAB case.
• The Office of the Solicitor General (OSG), for the OMB, argued that the finding of Simple Misconduct was supported by substantial evidence, including Baysa's admission that Santos was not involved in the case.

• Whether petitioner Andrew N. Baysa is administratively liable for simple misconduct for issuing orders in the execution of a DARAB decision that affected the property of respondent Marietta V. Santos, who was not a party to the original case.
• Whether an administrative complaint is the proper remedy for errors allegedly committed by a quasi-judicial officer in the exercise of his adjudicative functions.

• The Supreme Court granted Baysa's petition, reversing and setting aside the Court of Appeals' decision and resolution, and dismissed the administrative complaint for misconduct.
• The Court reiterated that disciplinary proceedings against judges (and quasi-judicial officers) are not complementary or suppletory of, nor a substitute for, judicial remedies. Exhaustion of judicial remedies and entry of judgment are prerequisites for administrative inquiry.
• Baysa's alleged infraction pertained to the exercise of his quasi-judicial functions, for which judicial remedies (appeal to DARAB, petition for review to CA, petition for certiorari to CA, and petition for review to SC) are available.
• Santos had, in fact, availed of a judicial remedy by filing a petition for certiorari (C.A. G.R. S.P. No. 118531), where the CA found Baysa committed grave abuse of discretion. However, there was no showing this CA decision had become final.
• Even if Baysa erred or committed grave abuse of discretion, this does not automatically translate to administrative liability unless there is a clear showing of bad faith.
• Misconduct requires wrongful, improper, or unlawful conduct motivated by a premeditated, obstinate, or intentional purpose. Santos failed to prove by substantial evidence that Baysa acted in bad faith or with ill-motive.
• Santos herself characterized Baysa's actions as "maling hatol" (erroneous judgment) and "maling akala" (mistaken belief), indicating errors in judgment rather than intentional wrongdoing.
• Baysa afforded Santos an opportunity to be heard by entertaining her motions, which militates against a finding of bad faith.

• Exhaustion of Judicial Remedies — This doctrine states that before a party may seek administrative redress against a judge or quasi-judicial officer for acts done in their official capacity, they must first avail themselves of, and exhaust, all available judicial remedies, and the challenged judicial action must have attained finality. The Court applied this by noting that administrative proceedings are not substitutes for judicial remedies to correct errors of judgment and that Santos had even availed of a judicial remedy (certiorari) whose finality was not established.
• Misconduct (Simple Misconduct) — Misconduct is defined as a wrongful, improper, or unlawful conduct motivated by a premeditated, obstinate, or intentional purpose. It is intentional wrongdoing or deliberate violation of a rule of law or standard of behavior. To constitute an administrative offense, misconduct should relate to or be connected with the performance of official functions. Simple misconduct lacks the elements of corruption, clear intent to violate the law, or flagrant disregard of an established rule found in grave misconduct. The Court found no substantial evidence of bad faith or ill-motive on Baysa's part to constitute even simple misconduct, viewing his actions as potential errors in judgment.
• Acts of a Judge in Judicial Capacity Not Subject to Disciplinary Action Without Bad Faith — A judge or quasi-judicial officer cannot be civilly, criminally, or administratively liable for official acts, no matter how erroneous, provided he acts in good faith. The Court emphasized that Santos failed to show Baysa acted in bad faith, and errors in judgment are to be corrected through judicial remedies, not administrative complaints.
• Substantial Evidence — This is the quantum of proof required in administrative proceedings, defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The Court found that Santos failed to meet this burden to prove Baysa was impelled by ill-motive.

• "Disciplinary proceedings against judges are not complementary or suppletory of, nor a substitute for, judicial remedies. Resort to and exhaustion of judicial remedies, as well as the entry of judgment in the corresponding action or proceeding, are pre-requisites for taking other measures against the judges concerned. It is only after the available judicial remedies have been exhausted and the appellate tribunals have spoken with finality, that the door to an inquiry into his or her criminal, civil, or administrative liability opens."
• "The Court declared that an administrative complaint is not the appropriate remedy for every act of a judge deemed aberrant or irregular where a judicial remedy exists and is available. The acts of a judge in his judicial capacity are not subject to disciplinary action. A judge cannot be civilly, criminally, or administratively liable for his official acts, no matter how erroneous, provided he acts in good faith."
• "Corollarily, misconduct is generally defined as the wrongful, improper, or unlawful conduct motivated by a premeditated, obstinate or intentional purpose. It is intentional wrongdoing or deliberate violation of a rule of law or standard of behavior."
• "On the contrary, Santos herself referred to Baysa's dispositions as mere errors in judgment, i.e.,'maling hatol' and 'maling akala' – nothing more..."

• Flores v. Abesamis — Cited to support the principle that disciplinary proceedings against judges are not substitutes for judicial remedies and require prior exhaustion of such remedies and finality of judgment.
• Atty. Tamondong v. Judge Pasal — Cited extensively as apropos to the case, emphasizing that errors committed by a judge in adjudicative functions should be assailed through judicial remedies, not administrative proceedings, unless bad faith is proven. It also highlighted that mere imputation of bias or an adverse judgment does not equate to bad faith.
• Field Investigation Office of the Office of the Ombudsman v. Castillo — Cited for the definition of misconduct and its elements, distinguishing between grave and simple misconduct.
• Hon. Ombudsman Simeon V. Marcelo v. Leopoldo F. Bungubung and the Court of Appeals — Cited for the definition of substantial evidence required in administrative cases.

• RA 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees) — Mentioned as the law Baysa was accused by the OMB of violating, though the specific provision was not cited by the OMB. The Supreme Court did not delve into this as it found no basis for administrative liability.
• DARAB Rules — Referenced in the context of C.A. G.R. S.P. No. 118531, where the Court of Appeals noted that under these rules, even necessary parties are required to be impleaded.