Delfin, Jennica Gyrl G.

Article 204. Knowingly rendering unjust judgment

A.M. No. 595-CFI December 11, 1978

QUINTIN STA. MARIA vs. HON. ALBERTO UBAY

Facts:
Quintin R. Sta Maria, attorney-in-fact of Valeriana Sta Maria, filed with the Supreme Court a letter-
complaint against Judge Q. Ubay for violating the provisions of Article 204 of the Revised Penal Code
when he knowingly rendered an unjust judgment by promulgating a decision contrary to the decisions of
the Supreme Court in previous related proceedings, violating section 11 of Article X of the 1973
Constitution, falsifying his decision in order to make it appear that he rendered the same within the statutory
three-month period and putting ever obstacle to the approval of their Record on appeal in spite of lack of
opposition duly filed on time. The letter-complaints were indorsed by the Assistant to the Judicial
Consultant to the respondent Judge for comment. In another letter complaint, Atty. Paz Palanca, branch
clerk of Clerk of respondent judge in his sala, was also charged with infidelity in the custody of judicial
records and, with putting all obstacles to the approval of their Record on Appeal. Sta. Maria states that the
respondent Judge in awarding to the plaintiffs (in Civil Case C-2052) in toto what they prayed for in their
complaint and amended complaint did so in bad faith and with full knowledge that said plaintiffs are not
entitled thereto.
Issue:
Whether or not respondent judge may be held liable under Art 204 of the Revised Penal Code.
Held:

No. the Court reiterates the ruled that in order that a judge may be held liable for knowingly rendering
an unjust judgment, it must be shown beyond doubt that the judgment is unjust in the sense that it is
contrary to law or is not supported by the evidence and the same was made with conscious and
deliberate intent to do an injustice. The rule requires that the judgment should be unjust for being
contrary to law and for not being supported by the evidence. In the case at bar, to determine whether
or not the decision of the respondent Judge in Civil Case C-2052 constitutes an unjust judgment would
involve more than a mere cursory reading of the decision itself or its comparison with this Court's
decisions invoked by the complainant. To delve into the different factors bearing on the issues raised
in Civil Case C-2052 considered by the respondent Judge in arriving at his conclusions set forth in the
decision in question for purposes of ascertaining the factual, legal and jurisprudential bases of the said
decision, would be tantamount to pre-empting the Court of Appeals of its appellate jurisdiction over
the case, considering that the same is pending before it. Indeed, this Court stated in Gahol vs. Hon.
Riodique that "only after the appellate court holds in a final judgment that a trial judge's alleged errors
were committed deliberately and in bad faith may a charge of knowingly rendering an unjust decision
be levelled against a trial judge." For, through an appeal, an aggrieved party can always point out, for
rectification by the appellate court, the errors in the alleged unjust judgment affecting him. The rule
also requires that the judgment should be rendered by the judge with conscious and deliberate intent
to do an injustice. In the case at bar, the complainant failed to show any unmistakable indication that
bad faith motivated the alleged unjust actuations of the respondent judge in Civil Case C-2052. Absent,
thus, any positive evidence on record that the respondent Judge rendered the judgment in question
with conscious and deliberate intent to do an injustice, the compliant must fall.

NEW CASE:
GR NO. 136769, SEPT. 17, 2002
BAN HUA U. FLORES V OFFICE OF THE OMBUDSMAN AND ATTY. ENRIQUE L. FLORES, JR.
Facts:
A complaint against the Ban Hua Flores for accounting and turnover of corporate funds of UBS Marketing
was instituted by Johnny K. H. Uy with the Securities and Exchange Commission. Petitioner moved for the
dismissal of the case on the ground of lack of jurisdiction which was denied. Likewise denied was the
appeal filed with the SEC en banc. A judgment was rendered in favor of the complainant. Petitioner Flores
and company then appealed to the SEC en banc which reversed the decision except the order of accounting.
A criminal complaint was then filed by the petitioner alleging that Hearing Officer Enrique Flores rendered
an unjust judgment under Art. 204 of the RPC and violating Sec. 3 of RA 3019 (Anti-Graft and Corrupt
Practices Act) which was dismissed by the Office of Ombudsman for insufficiency of evidence ratiocinating
that there was no showing that the decision was rendered maliciously and deliberately to do an injustice to
the complainant and that the error was committed in good faith pursuant to the principle of regularity in the
performance of official functions. It was well settled that a judicial officer, when required to exercise his
judgment or discretion is not criminally liable for any error which he commits provided he acts in good
faith. Even though the complainant had been inconvenienced because of the decision of the respondent,
such inconvenience did not amount to causing undue injury under Sec. 3 of RA 3019, not only because
there is no showing of evident bad faith or inexcusable negligence but because the decision appealed to the
SEC en banc was immediately corrected, hence said decision did not become final and executory. Petitioner
moved for the reconsideration which was likewise denied. Hence this petition where petitioner contends
that public respondent committed grave abuse of discretion in dismissing the complaint, alleging that the
decision was not made in good faith since the case did not involve a complex question of law but was a
plain violation of simple rules of procedure and that petitioner and her family suffered undue injury as result
of the decision, making respondent liable under Sec. 3 of RA 3019.
Issue: Whether the Office of the Ombudsman committed grave abuse of discretion in dismissing the
complaint against private respondent for violation of Article 204 of the Revised Penal Code and Section 3
(e) of RA 3019, otherwise known as the Anti-Graft and Corrupt Practices Act.
Held:
No. There is grave abuse of discretion where the respondent acts in a capricious, whimsical, arbitrary or
despotic manner in the exercise of his judgment,13 as when the assailed order is bereft of any factual and
legal justifications. In this case, the Court found that the assailed resolution of the Office of the Ombudsman
dismissing the complaint against private respondent was legally justified. This is so because before one can
be held liable under Article 204 of the Revised Penal Code and Section 3 (e) of RA 3019, the person subject
of the complaint must be shown to have committed the act in bad faith. It was held in Guerrero vs. Villamor,
296 SCRA 88, 98 (1998), that a judge will be held liable for rendering an unjust judgment where he acts in
bad faith, malice, revenge or some other similar motive. In Ingco vs. Sandiganbayan, 272 SCRA 563, 574
(1997), the Court clearly indicated, as one of the elements of the offense under Section 3 (e) of RA 3019,
that the public officer complained of should have acted with manifest partiality, evident bad faith or gross
inexcusable negligence. In this case, the Office of the Ombudsman did not find private respondent in bad
faith, hence, the important element for the above offenses is wanting. Notice should also be made of the
fact that under Article 204 of the Revised Penal Code, the offender must be a judge. In this case, the alleged
offender is a hearing officer of the SEC. Neither does the assailed resolution lack factual justification
because petitioner failed to overcome the burden of proof to show private respondent’s bad faith.