Villamor vs. Salas

A Regional Trial Court may not take cognizance of an action for damages against a judge of another co-equal Regional Trial Court for an allegedly unjust judgment or order; only the Court of Appeals and the Supreme Court may review and correct errors of trial courts, and a judge is not liable for an erroneous decision absent malice or wrongful conduct.

Judge Adriano R. Villamor presided over Civil Case No. B-398 and related criminal cases involving George Carlos and Gloria Naval. Attorney Antonio T. Guerrero acted as Carlos's counsel in those proceedings. The present consolidated petitions concern the authority of Regional Trial Court Judges Bernardo LL. Salas and Peary G. Aleonar to hear separate damages actions filed against Judge Villamor arising from his judicial orders in the earlier litigation. Philippine procedure vests authority to review and correct errors of trial courts in the Court of Appeals and the Supreme Court.

Judge Adriano R. Villamor presided over Civil Case No. B-398, an action filed in 1977 by Gloria Naval against George Carlos for recovery of ownership of a parcel of coconut land. While that civil case was pending, Carlos filed Criminal Cases Nos. N-989 to N-993 for qualified theft against Naval and her helpers; those cases were also assigned to Judge Villamor and were temporarily archived because of the pendency of Civil Case No. B-398. After trial, Judge Villamor rendered judgment in favor of Naval, declaring her the lawful owner and possessor of the disputed land and ordering Carlos to vacate it.

Carlos, through counsel, moved to activate the archived criminal cases. Because Judge Villamor had already declared Naval the lawful owner and possessor in Civil Case No. B-398, he dismissed the criminal cases against Naval and her co-accused. He also granted execution pending appeal of his civil-case decision; Carlos challenged that order in the Court of Appeals and in the Supreme Court, both without success. Carlos then filed an administrative case, A.M. No. RTJ-87-105, against Judge Villamor for allegedly issuing illegal orders and an unjust decision in Civil Case No. B-398. On November 21, 1988, the Supreme Court En Banc summarily dismissed the administrative case.

Dissatisfied, Carlos filed Civil Case No. CEB-6478 for damages against Judge Villamor for knowingly rendering an unjust judgment in dismissing the five criminal cases against Naval and others. Summons in that case was served on Judge Villamor on December 10, 1987. The next day, instead of answering, Judge Villamor issued in Criminal Cases Nos. N-0989 to 0993 an order of direct contempt against Carlos and his lawyer, Attorney Antonio T. Guerrero, for degrading the respect and dignity of the court through derogatory and contemptuous language, and sentenced each to five days' imprisonment and a P500 fine.

Carlos immediately filed a petition for certiorari in the Supreme Court (G.R. Nos. 82238-42) with a prayer for preliminary injunction. The Supreme Court restrained Judge Villamor from enforcing the contempt order and, on November 13, 1989, annulled the order. Meanwhile, Judge Villamor moved to dismiss Civil Case No. CEB-6478 for lack of jurisdiction. The trial court granted the motion; the Court of Appeals affirmed on June 26, 1990 (CA-G.R. CV No. 20657), and the Supreme Court denied Carlos's petition.

Carlos and Attorney Guerrero then filed separate complaints for damages against Judge Villamor for knowingly rendering an unjust order of contempt. Guerrero's complaint, Civil Case No. CEB-8802, was raffled to Branch 21, Regional Trial Court, Cebu City, presided over by Judge Peary G. Aleonar. Carlos's complaint, Civil Case No. CEB-8823, was raffled to Branch 8, Regional Trial Court of Cebu City, presided over by Judge Bernardo LL. Salas. Judge Villamor filed a motion to dismiss CEB-8802 on March 30, 1990, but Judge Aleonar denied it. On May 20, 1991, Judge Villamor filed a Manifestation praying Judge Salas to dismiss CEB-8823; Judge Salas denied it on July 2, 1991. These denials led to the consolidated petitions for certiorari and prohibition.

• Lack of Jurisdiction: Petitioner Judge Villamor maintained that the Regional Trial Court lacked jurisdiction over the damages action, as reflected in his motion to dismiss Civil Case No. CEB-8802; Judge Aleonar denied the motion.
• Dismissal of the Damages Action: Petitioner sought dismissal of Civil Case No. CEB-8823 through a Manifestation filed on May 20, 1991; Judge Salas denied it on July 2, 1991. The decision does not state the ground relied upon in that Manifestation.

• Jurisdiction of Co-Equal Courts: Whether Judges Aleonar and Salas may take cognizance of the actions for damages against Judge Villamor for allegedly having rendered an unjust order of direct contempt against Carlos and Attorney Guerrero which the Supreme Court subsequently annulled.

• Jurisdiction of Co-Equal Courts: No. A Regional Trial Court cannot take cognizance of an action for damages against a co-equal Regional Trial Court judge for an allegedly unjust judgment or order; only the Court of Appeals and the Supreme Court may review and correct errors of trial courts, and no malice or bad faith was declared in the annulment.

• Jurisdiction of Co-Equal Courts: The Court relied on its prior resolution in George D. Carlos vs. CA, which held that no Regional Trial Court can pass upon and scrutinize, much less declare unjust, a judgment of another Regional Trial Court and sentence the judge liable for damages, because only the Court of Appeals and the Supreme Court are vested with authority to review and correct errors of trial courts. Allowing Judges Aleonar and Salas to proceed would permit a court to review and interfere with the judgment of a co-equal court over which it has no appellate jurisdiction or power of review; branches of a Court of First Instance, now Regional Trial Court, are co-equal and may not interfere with each other's cases, judgments, and orders (Parco vs. Court of Appeals). The Court further explained that only after an appellate court, in a final judgment, has found that a trial judge's errors were committed deliberately and in bad faith may a charge of knowingly rendering an unjust decision be levelled against the judge (Garcia vs. Alconcel; Sta. Maria vs. Ubay; Gahol vs. Riodique). The decision annulling Judge Villamor's direct contempt order contained no declaration that the erroneous order was rendered maliciously or with conscious and deliberate intent to commit an injustice; a previous direct contempt order against Carlos's former counsel had even been sustained (Jaynes C. Abarrientos, et al. vs. Judge Villamor). At most, the nullified contempt order was an error of judgment for which Judge Villamor could not be held criminally or civilly liable, since a judge is not liable for an erroneous decision absent malice or wrongful conduct (Barroso vs. Arche). Thus the damages actions could not be entertained by the respondent judges.

• Non-Interference Among Co-Equal Courts — A Regional Trial Court cannot pass upon, scrutinize, or declare unjust the judgment or order of another co-equal Regional Trial Court, nor sentence that court's judge liable for damages, because only the Court of Appeals and the Supreme Court are vested with authority to review and correct errors of trial courts. The Court applied this principle to bar the damages actions against Judge Villamor before Judges Aleonar and Salas.
• Judicial Immunity for Erroneous Decisions — A judge is not criminally or civilly liable for an erroneous decision or order in the absence of malice or wrongful conduct in rendering it. The Court found no such malice or wrongful conduct in the annulment of the contempt order; at most, the order was an error of judgment.
• Knowingly Rendering an Unjust Decision — A charge of knowingly rendering an unjust decision may be levelled only after the appellate court, in a final judgment, has found that the trial judge's errors were committed deliberately and in bad faith. The Court held that the annulment of the contempt order did not satisfy this requirement.

• "Indeed, no Regional Trial Court can pass upon and scrutinize, and much less declare as unjust a judgment of another Regional Trial Court and sentence the judge thereof liable for damages without running afoul with the principle that only the higher appellate courts, namely, the Court of Appeals and the Supreme Court, are vested with authority to review and correct errors of the trial courts." — Quoted by the Court from its prior resolution in George D. Carlos vs. CA; it states the core jurisdictional rule barring the damages actions.
• "To allow respondent Judges Aleonar and Salas to proceed with the trial of the actions for damages against the petitioner, a co-equal judge of a co-equal court, would in effect permit a court to review and interfere with the judgment of a co-equal court over which it has no appellate jurisdiction or power of review." — This passage applies the co-equal-court principle to the consolidated petitions.
• "This Court has already ruled that only after the Appellate Court, in a final judgment, has found that a trial judge's errors were committed deliberately and in bad faith may a charge of knowingly rendering an unjust decision be levelled against the latter (Garcia vs. Alconcel, 111 SCRA 178; Sta. Maria vs. Ubay, 87 SCRA 179; Gahol vs. Riodique, 64 SCRA 494)." — This states the requisite for a knowingly-rendering-unjust-decision charge.
• "At most, the order of direct contempt which we nullified may only be considered an error of judgment for which Judge Villamor may not be held criminally or civilly liable to the respondents." — This applies the malice requirement to the annulled contempt order.

• George D. Carlos vs. CA, G.R. No. 95560, November 5, 1990 — Prior resolution quoted by the Court; held no Regional Trial Court can pass upon and scrutinize, much less declare unjust, a judgment of another Regional Trial Court and sentence its judge liable for damages.
• Parco vs. Court of Appeals, 111 SCRA 262 — Cited for the rule that co-equal branches of the Court of First Instance, now Regional Trial Court, may not interfere with each other's cases, judgments, and orders.
• Garcia vs. Alconcel, 111 SCRA 178 — Cited for the requirement that only after an appellate court final judgment finds deliberate and bad-faith errors may a charge of knowingly rendering an unjust decision be levelled.
• Sta. Maria vs. Ubay, 87 SCRA 179 — Cited for the same requirement regarding deliberate and bad-faith errors.
• Gahol vs. Riodique, 64 SCRA 494 — Cited for the same requirement regarding deliberate and bad-faith errors.
• Jaynes C. Abarrientos, et al. vs. Judge Villamor, G.R. No. 82237, June 1, 1988 — Cited to show a previous direct contempt order by Judge Villamor against Carlos's former counsel was sustained, supporting the absence of malice in the later annulled order.
• Barroso vs. Arche, 67 SCRA 161 — Cited for the rule that a judge is not liable for an erroneous decision absent malice or wrongful conduct.

Chief Justice Narvasa, Justices Cruz, Feliciano, and Medialdea concurred.