HENRY GIBAGA PAMPLONA COMPLAINANT, VS. HON. ANTONIO GEOFFREY H. CANJA, PRESIDING JUDGE, MUNICIPAL TRIAL COURT [MTC], POLOMOLOK, SOUTH COTABATO, RESPONDENT.

Pamplona versus Canja

The Case

This is an administrative complaint filed by Henry Gibaga Pamplona against Judge Antonio Geoffrey H. Canja, the presiding judge of the Municipal Trial Court of Polomolok, South Cotabato. Pamplona charges the judge with gross ignorance of the law or procedure, constituting violations of the Code of Judicial Conduct, arising from the judge's handling of a quieting of title case involving the Pamplona heirs. The case matters because it draws the line between a judge's honest correction of his own judgment within the reglementary period and that species of gross, patent, deliberate error which alone warrants administrative discipline. It also reminds every reviewee that a losing litigant's remedy against an erroneous judgment lies in judicial remedies, not in an administrative complaint.

Procedural History

The controversy began in the Municipal Trial Court of Polomolok, South Cotabato, in a civil case for quieting of title, declaration of nullity of sales, cancellation of land titles and tax declarations. On March 1, 2024, Judge Canja rendered a decision partially in favor of the Pamplona heirs, ordering Spouses Loreto and Edith Dalisay to execute a deed of reconveyance over a particular lot. After the Dalisays filed an ex parte manifestation, the judge treated it as a motion for reconsideration, set it for hearing, denied the heirs' motion for execution on the ground that the decision had not attained finality, and then issued an amended decision dismissing the civil case. Pamplona then filed this administrative complaint directly with the Supreme Court. The Judicial Integrity Office investigated and recommended that the judge be found guilty of gross ignorance of the law or procedure and fined 50,000 pesos. The Supreme Court, in its decision, dismissed the complaint for lack of merit.

Facts

The civil case concerned a three-hectare portion of an eight-hectare parcel of land in South Cotabato, previously covered by Transfer Certificate of Title No. T-33149. On March 1, 2024, Judge Canja rendered a decision partially in favor of the Pamplona heirs, directing Spouses Dalisay to execute a deed of reconveyance over Lot No. 2536-B-2, covered by Transfer Certificate of Title No. 145-2019002694.

On March 27, 2024, thirteen days after their counsel received the decision on March 14, 2024, Spouses Dalisay filed an ex parte manifestation. They expressed willingness to abide by the ruling but asserted that the property to be reconveyed was not Lot No. 2536-B-2 but Lot No. 2536-B-3, covered by Transfer Certificate of Title No. 145-2019002695, the lot they actually occupied. The same day, Judge Canja issued an order treating the manifestation as a motion for reconsideration and setting it for hearing on April 24, 2024. The hearing was reset because plaintiffs' counsel had not received a copy of the manifestation.

The Pamplona heirs then filed a vehement opposition with a motion for execution, arguing that the decision had already become final and that the manifestation could not be converted into a motion. On May 14, 2024, Judge Canja denied the motion for execution, explaining that the decision had not attained finality and that he was acting under the court's inherent power to amend and control its processes. Two days later, on May 16, 2024, he issued an amended decision dismissing the civil case, holding that a statement in the Dalisays' judicial affidavit was an offer to compromise and therefore inadmissible, and that the plaintiffs had failed to prove their case by preponderance of evidence. Pamplona then filed this administrative complaint, also alleging that the judge lost his temper.

Issues

• Whether or not Judge Canja is administratively liable for gross ignorance of the law or procedure when he treated the ex parte manifestation as a motion for reconsideration, set the civil case for further hearing, and amended his decision.
• Whether or not the administrative complaint is the proper remedy against the judge's acts in the exercise of his adjudicative functions.
• Whether or not the allegation that the judge lost his temper was established by substantial evidence.

Applicable Provisions

Rule 135, Section 5(g) of the Rules of Court, on the court's inherent power, provides:

Section 5. Inherent powers of courts. — Every court shall have power: x x x (g) To amend and control its process and orders so as to make them conformable to law and justice.

This is the provision the Court invokes to uphold the judge's act of amending his own decision within the reglementary period.

Rule 40, Section 2 of the Rules of Court, on the period to appeal from a municipal trial court decision, provides:

Section 2. Period of appeal. — The appeal shall be taken within fifteen (15) days after notice of the judgment or final order appealed from.

This fixes the reglementary period within which the judge could still amend his judgment, and which had not yet lapsed when he acted.

Ruling

On the first issue, the Court held that the complaint is unmeritorious. Gross ignorance of the law or procedure means the disregard of basic rules and settled jurisprudence, or the commission of a gross or patent, deliberate or malicious error. Here, the judge did not commit such error. Although the pleading was captioned an ex parte manifestation, its body argued that the court erred in designating the property and prayed for a substantial amendment, so it was in truth a motion. The judge acted prudently in setting it for hearing rather than amending outright, because in actions to recover title the identity of the property, including its location, area, and boundaries, is material. The Court also found that the manifestation was served on Pamplona's counsel by registered and electronic mail, that the judge set it for hearing three times, and that the heirs filed a vehement opposition which the judge resolved before issuing the amended decision. Due process was therefore observed.

Even without a motion, the Court held, the judge could motu proprio amend his decision under Rule 135, Section 5(g), which authorizes a court to amend, modify, or reverse its judgment within the reglementary period to make it conformable to law and justice. The Dalisays received the decision on March 14, 2024, and the judge acted on March 27, 2024, only thirteen days later, within the fifteen-day period. The judge was also not bound by the parties' arguments and could decide on the evidence and the law.

On the second issue, the Court held that errors in the exercise of adjudicative functions cannot be corrected through administrative proceedings but must be assailed through available judicial remedies. Resort to and exhaustion of judicial remedies are prerequisites to disciplinary measures against judges. Since the acts complained of pertained to the judge's adjudicative functions and no judicial remedy had been exhausted, dismissal was warranted. Absent fraud, dishonesty, or corruption, the acts of a judge in his judicial capacity are not subject to disciplinary action.

On the third issue, the Court held that the bare allegation that the judge lost his temper was unsubstantiated, as complainants must establish their claims by substantial evidence.

Doctrine

First, gross ignorance of the law or procedure is the disregard of basic rules and settled jurisprudence, or a gross or patent, deliberate or malicious error; it cannot be excused by a claim of good faith, but neither is it presumed from a mere error in judgment.

Second, whether a paper is a manifestation or a motion is determined not by its caption but by its body and the relief it seeks.

Third, under Rule 135, Section 5(g), a court may, upon motion or motu proprio, amend, modify, or reverse its own judgment provided that it honestly believes there is an error, that the amendment is made within the reglementary period, and that it is undertaken to make the judgment conformable to law and justice.

Fourth, errors committed by a judge in the exercise of adjudicative functions are corrected through judicial remedies, not administrative complaints; exhaustion of judicial remedies is a prerequisite to disciplinary action.

Disposition

The Supreme Court dismissed the administrative complaint against Judge Canja for lack of merit, and the judge was exonerated.

Remember This

Memorize this line: a judge may motu proprio amend or reverse his own judgment within the reglementary period under Rule 135, Section 5(g), and an error in the exercise of adjudicative functions is corrected by appeal, not by an administrative complaint. Examiners use this case to test the inherent power of courts to amend their own processes and the rule on exhaustion of judicial remedies before filing disciplinary complaints against judges.