GENARO SANTIAGO III v. JUSTICE JUAN Q. ENRIQUEZ, JR.

579 SCRA 1 (2009) Under

the principle of judicial immunity, judges cannot be held criminally, civilly or
administratively liable for an erroneous decision rendered in good faith.
The complainant Genaro Santiago III filed a Petition for Reconstitution of Lost/
Destroyed Original Certificate of Title No. 56, registered in the name of Pantaleona
Santiago and Blas Fajardo. The Regional Trial Court of Quezon City granted the
petition. The Republic of the Philippines, through the Office of the Solicitor General,
appealed to the Supreme Court asking for its reversal.
The case was raffled to Justice Marlene Gonzales-Sison, Justice Vicente Veloso and
herein respondent Justice Juan Enriquez. Justice Gonzales-Sison was the one who
made the Report as the basis for the Divisions consultation and deliberation which
upholds the decision made by the RTC of Quezon City. Justice Veloso concurred in
the Report made. On the other hand, Justice Enriquez dissented to the Report and
made his own Dissenting Opinion. Justice Enriquez requested for another two (2)
Justices to form a Special Division, Justice Edgardo Cruz and Justice Lucas Bersamin
were then included. After the deliberations, the Dissenting Opinion of Justice
Enriquez became the majority opinion. The decision of the RTC of Quezon City was
reversed by the decision made by the Special Division.
Complainant Santiago then filed an administrative complaint against Justice
Enriquez on the ground of gross ignorance of the law, and gross incompetence in
connection with his rendering of alleged unjust judgment in the case of Santiago.
Justice Enriquez contends that it was a mere nuisance and that it was filed
prematurely.
ISSUE: Whether or not there is a valid ground for the filing of an administrative case
against Justice Enriquez
HELD: The Court has to be shown acts or conduct of the judge clearly indicative of
the arbitrariness or prejudice before the latter can be branded the stigma of being
biased and partial. Thus, unless he is shown to have acted in bad faith or with
deliberate intent to do an injustice, not every error or mistake that a judge commits
in the performance of his duties renders him liable.
The principle of judicial immunity insulates judges, and even Justices of superior
courts, from being held to account criminally, civilly or administratively for an
erroneous decision rendered in good faith. To hold otherwise would render judicial
office untenable. No one called upon to try the facts or interpret the law in the
process of administering justice could be infallible in his judgment.
It bears particular stress in the present case that the filing of charges against a
single member of a division of the appellate court is inappropriate. The Decision was
not rendered by respondent in his individual capacity. It was a product of the
consultations and deliberations by the Special Division of five.