Fabiana vs. Reyes, Jr.

Administrative complaints for willful disobedience against judges cannot prosper where the challenged act constitutes a valid exercise of judicial discretion in resolving distinct legal issues, and consolidation of related cases at the appellate stage is mandatory where the cases involve the same parties and related questions of fact or law to prevent conflicting results and enhance judicial administration.

Marlon Fabiana, a seafarer employed by Magsaysay Maritime Corporation, died while under contract. His surviving spouse, Merlita B. Fabiana, and heirs filed a claim for death benefits and other monetary claims before the Labor Arbiter. The Labor Arbiter ruled in their favor, awarding substantial damages. The National Labor Relations Commission modified the decision by reducing the moral and exemplary damages. Both parties filed separate petitions for certiorari before the Court of Appeals, resulting in two distinct cases assigned to different divisions. The heirs sought consolidation of these petitions, but the CA failed to act on the request, leading to separate proceedings and conflicting postures regarding the finality of awards.

• The Labor Arbiter's Award: On December 19, 2007, the Labor Arbiter granted the heirs of Marlon Fabiana death benefits totaling US$82,500.00 to the surviving spouse, US$16,500.00 to the son, salary differentials, sick benefits, guaranteed overtime pay, actual damages of ₱7,574.00, moral damages of ₱100,000.00, exemplary damages of ₱1,000,000.00, and ten percent attorney's fees.
• NLRC Modification: On December 10, 2008, the National Labor Relations Commission modified the Labor Arbiter's decision, reducing the moral and exemplary damages to ₱50,000.00 each while affirming the other awards.
• The Two Certiorari Petitions: The parties filed separate petitions for certiorari before the Court of Appeals. The first petition (C.A.-G.R. SP No. 109382), filed by the heirs, assailed the NLRC's jurisdiction over the employer's appeal and sought reinstatement of the original damage awards. The second petition (C.A.-G.R. SP No. 109699), filed by Magsaysay Maritime Corporation and its principal, challenged the propriety of the monetary awards for death benefits, sickness allowance, and salary differentials, claiming the seafarer's death was non-work related and occurred after contract termination.
• Consolidation Request: On August 20, 2009, the heirs filed a comment vis-à-vis the second petition, seeking consolidation of the two petitions. The CA did not act on this request.
• First CA Decision: On September 29, 2009, the First Division of the CA (Associate Justice Bruselas, Jr., ponente) promulgated its decision on the first petition, affirming the NLRC decision with modifications regarding the imposition of six percent per annum interest on monetary awards and twelve percent per annum interest from finality until full payment.
• Supreme Court Resolution: The heirs appealed to the Supreme Court via petition for review on certiorari (G.R. No. 189726). On January 13, 2010, the Third Division denied the petition for failure to show reversible error.
• Motion to Dismiss in Second Petition: On October 16, 2009, the heirs moved to dismiss the second petition (C.A.-G.R. SP No. 109699), arguing it was rendered moot by the September 29, 2009 decision in the first petition. On June 4, 2010, the First Division of the CA (Presiding Justice Reyes, Jr., Associate Justice Dicdican ponente, Associate Justice Cruz) denied the motion to dismiss, holding that the first petition only resolved limited issues (NLRC jurisdiction and damages reduction) while the second petition assailed the propriety of all monetary awards.
• Resolution of Second Petition: The second petition was ultimately dismissed by the Sixth Division of the CA on September 16, 2011, finding no grave abuse of discretion by the NLRC.
• The Administrative Complaint: Complainant Merlita B. Fabiana accused the three CA Justices of willful disobedience of the Supreme Court's January 13, 2010 resolution, claiming it had fixed her claims with finality, thereby rendering the second petition moot.

• Willful Disobedience: Complainant maintained that the Supreme Court's resolution of January 13, 2010 in G.R. No. 189726 had fixed her claims for death benefits with finality, and that the respondent Justices openly defied this resolution by denying the motion to dismiss in the second petition, thereby acting with deliberate bad faith.
• Mootness: Petitioner argued that the second petition was rendered moot and academic by the decision in the first petition and the Supreme Court's resolution denying review thereof.

• Distinct Issues: Respondent Justices countered that the first petition (C.A.-G.R. SP No. 109382) only resolved two limited issues: the NLRC's jurisdiction over the appeal and the propriety of reducing moral and exemplary damages. In contrast, the second petition (C.A.-G.R. SP No. 109699) concerned the propriety of awarding death benefits, sickness allowance, salary differentials, and other monetary claims, requiring separate adjudication.
• Judicial Discretion: Respondents argued that the denial of the motion to dismiss was issued in the exercise of judicial discretion, not willful disobedience, and that the complainant's recourse was to seek judicial review of the resolution, not to file an administrative complaint.

• Willful Disobedience: Whether respondent CA Justices committed willful disobedience by denying the motion to dismiss in C.A.-G.R. SP No. 109699 despite the Supreme Court's resolution in G.R. No. 189726 denying the petition for review on certiorari in the related case.
• Consolidation of Related Cases: Whether the CA erred in failing to consolidate the two related petitions involving the same parties and arising from the same set of facts.

• Willful Disobedience: The charge of willful disobedience was unsubstantiated and baseless. The Supreme Court's resolution of January 13, 2010 did not divest the CA First Division of jurisdiction over the second petition because the two petitions involved distinct issues. The first petition only resolved questions of jurisdiction and damages reduction, while the second petition assailed the propriety of the monetary awards themselves. The denial of the motion to dismiss was a valid exercise of judicial discretion, and administrative complaints cannot substitute for appropriate judicial remedies such as motion for reconsideration or certiorari.
• Consolidation of Related Cases: The CA should have consolidated the two petitions as they involved the same parties, the same facts, and related questions of law. While consolidation at the trial stage is permissive, consolidation at the appellate stage is mandatory to prevent conflicting results and to fulfill the dual function of appellate courts (review for correctness and institutional function). The CA's failure to consolidate violated Section 3(a), Rule III of the 2009 Internal Rules of the Court of Appeals.

• Administrative Remedies as Non-Substitutes for Judicial Review — Administrative or criminal remedies against judges are neither alternative nor cumulative to judicial review where such review is available, and must wait on the result thereof. Allowing collateral attacks through administrative complaints would confer upon prosecutors or the Ombudsman the incongruous function of reviewing judicial dispositions, leading to interminable and vexatious litigation.
• Judicial Error vs. Administrative Liability — A judge's failure to correctly interpret the law or appreciate evidence does not necessarily incur administrative liability. Administrative sanction and criminal liability should be visited only when the error is so gross, deliberate and malicious, or committed with evident bad faith, or in clear cases of violations of standards of propriety and good behavior.
• Mandatory Consolidation at the Appellate Stage — At the appellate stage, consolidation of cases resting on the same set of facts or involving identical claims, interests, or parties is mandatory, not merely permissive. This rigid policy eliminates conflicting results concerning similar issues and enhances the administration of justice by fulfilling the dual function of appellate courts: review for correctness and the institutional function of developing the law.
• Dual Function of Appellate Courts — An appellate court serves a dual function: (1) the review for correctness function, ensuring substantial justice in the particular case, and (2) the institutional function, referring to the progressive development of the law for general application. With each level of the appellate structure, the review for correctness function diminishes while the institutional function increases.

• "Given the nature of the judicial function, the power vested by the Constitution in the Supreme Court and the lower courts established by the law, the question submits to only one answer: the administrative or criminal remedies are neither alternative nor cumulative to judicial review where such review is available, and must wait on the result thereof." — Citing In Re: Joaquin T. Borromeo, this passage establishes that administrative complaints cannot substitute for judicial remedies.
• "A judge's failure to correctly interpret the law or to properly appreciate the evidence presented does not necessarily incur administrative liability, for to hold him administratively accountable for every erroneous ruling or decision he renders, assuming he has erred, will be nothing short of harassment and will make his position doubly unbearable." — This clarifies the standard for holding judges administratively liable.
• "In the appellate stage, therefore, the rigid policy is to make the consolidation of all cases and proceedings resting on the same set of facts, or involving identical claims or interests or parties mandatory. Such consolidation should be made regardless of whether or not the parties or any of them requests it." — This establishes the mandatory nature of consolidation at the appellate level.

• In Re: Joaquin T. Borromeo, A.M. No. 93-7-696-0, February 21, 1995, 241 SCRA 405 — Controlling precedent establishing that administrative and criminal remedies against judges are not alternatives to judicial review.
• In Re: Verified Complaint of Engr. Oscar L. Ongjoco, A.M. OCA I.P.I. No. 11-184-CA-J, January 31, 2012, 664 SCRA 465 — Followed for the proposition that judges are not administratively liable for errors of judgment absent gross negligence or bad faith.
• Caños v. Peralta, No. L-38352, August 19, 1982, 115 SCRA 843 — Cited for the rule on consolidation of cases involving common questions of law or fact.
• Heirs of Trinidad De Leon Vda. de Roxas v. Court of Appeals, G.R. No. 138660, February 5, 2004, 422 SCRA 101 — Cited for the definition of substantial identity of parties.
• Hacienda Bigaa, Inc. v. Chavez, G.R. No. 174160, April 20, 2010, 618 SCRA 559 — Cited for the standard regarding identity of issues in consolidation.

• Section 3(a), Rule III, 2009 Internal Rules of the Court of Appeals — Mandates consolidation of related cases assigned to different Justices when they involve the same parties and/or related questions of fact and/or law. The Court directed the CA to amend this to make consolidation mandatory.
• Section 5, Rule 7, Rules of Court — Cited regarding attorneys' undertakings in certifications against forum-shopping to report related pending cases.
• Section 1, Rule 31, Rules of Court — Provision on consolidation of civil trials (permissive at trial stage).
• Section 22, Rule 119, Rules of Court — Provision on consolidation of criminal trials.

Sereno, C.J., Carpio, Velasco, Jr., Leonardo-De Castro, Brion, Peralta, Del Castillo, Abad, Villarama, Jr., Perez, Mendoza, Reyes, Perlas-Bernabe, and Leonen, JJ.