Facts
Maria Magdalena R. Joven filed a Letter-Complaint and Supplemental Complaint against Judge Monique A. Quisumbing-Ignacio, Sheriff Victor M. Pe Benito, and Administrative Aide Alfredo Marcelo Bermejo, all of Branch 209, RTC Mandaluyong City, for gross ignorance of the law, gross misconduct, conduct prejudicial to the best interest of the service, and violations of the New Code of Judicial Conduct. The charges arose from orders in Civil Case No. R-MND-18-00315-CV, where Sison sued to recover land from Joven; Joven claimed the judge denied her motions while granting Sison's, issued a Writ of Preliminary Mandatory Injunction, and later a Warrant of Arrest for indirect contempt that kept her imprisoned until she complied. Joven's own Rule 65 petition before the Court of Appeals assailing the same issuances was dismissed for being filed out of time. The judge later inhibited, the case settled by compromise, and Joven vacated the property. The Judicial Integrity Board recommended dismissing the complaint against all three respondents.
Issue
May a judge be held administratively liable for orders issued in the exercise of judicial discretion in a pending civil case, absent a prior judicial determination that the orders were erroneous or made in bad faith?
Ruling
No. The Court held 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," citing Biado v. Hon. Brawner-Cualing, which held that a judge's acts in their judicial capacity are not subject to disciplinary action and that a judge cannot be civilly, criminally, or administratively liable for official acts, no matter how erroneous, provided they acted in good faith. Citing Bello III v. Judge Diaz, the Court explained that disciplinary proceedings against judges do not substitute for judicial remedies, and that administrative liability for judicial acts may be inquired into only after other available remedies have been settled. The Court found Joven's grievances went to the judge's exercise of judicial discretion, and that she failed to prove bad faith or bias by substantial evidence — which, per Sampiano v. Judge Indar, imputes "a dishonest purpose or some moral obliquity and conscious doing of a wrong." It likewise found no substantial evidence against the sheriff or the administrative aide. The Complaint against all three respondents was DISMISSED for lack of merit and for being judicial in nature.