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LEAÑO, JASMINE

Article III. Section 1. Procedural Due Process. Judicial Proceedings. Aspects of the Proceedings
Almendras v. Asis – 330 SCRA 69 [2000]
FACTS: Petitioner Antonio Almendra filed 3 administrative complaints against Judge Enrique Asis of RTC
Leyte for partiality, gross ignorance of the law, knowingly rendering unjust judgment, and violation of the
Anti-Graft and Corrupt Practices Act.
Gaudencio Almendra, sibling of the petitioner, filed with the RTC an action for quieting of title over
several parcels of land located in Abuyog, Leyte. The trial court declared plaintiff Gaudencio Almendra
and defendants Francisco, Vicente, and Antonio Almendra co-owners of the parcels of land in question.
The case was appealed to the CA and the CA affirmed the decision of the trial court.
Thelma and Arthur Almendra, legitimate children of Gaudencio, filed an action for quieting of title, with
Antonio as one of the defendants. Judge Enrique Asis declared Thelma and Arthur Almendra the rightful
owners. Antonio Almendra (petitioner) filed an administrative complaint against Judge Asis for failing to
observe the doctrine of res judicata. Respondent judge averred that his decision merely implemented the
CA’s decision and further claims that the decision was in favor of petitioner since the land delineated to
him was greater in area and productivity than the others.
Petitioner filed the second administrative complaint against respondent judge for issuing a writ of
possession against Antonio and in favor of a certain Refugia Dictado concerning 3 parcels of land. In his
defense, Judge Asis stated that petitioner did not enjoy any right to possess the subject parcel of land
because of his own admission that Refugia Dictado was the owner of the land in question.
Lastly, Antonio filed a complaint for libel against a retired fiscal, Eloodoro Alvero. Respondent judge
issued a warrant of arrest but later dismissed the information for lack of probable cause. Petitioner filed the
third administrative complaint, alleging that Judge Asis exhibited manifest partiality against him so the
latter should inhibit himself from all pending cases involving Antonio.
ISSUES/HELD:
1. W/N respondent judge failed to observe the doctrine of res judicata. YES
a. The doctrine of res judicata has the following requisites: the former judgment must be final; (b) the
court which rendered it had jurisdiction over the subject matter and the parties; (c) it must be a
judgment on the merits; and (d) there must be, between the first and second actions, identity of
parties, subject matter and causes of action.
• Respondent judge’s decision on the quieting of the title clearly manifests that the issues,
parties and subject matter are identical. A judge cannot modify a final decision, especially if
it was decided upon by an appellate court. Moreover, the argument that a decision is
favorable to a party runs contrary to the respondent’s earlier claim that the land was equally
divided among the co-owners.
• “When material facts or questions which were in issue in a former action and were admitted
or judicially determined there are conclusively settled by a judgment rendered therein, such
facts or questions become res judicata and may not again be relitigated in a subsequent
action between the same parties of their privies regardless of the form of the latter."
2. W/N respondent judge exhibited manifest partiality against the petitioner. NO
a. A judge will be administratively liable for promulgating an unjust judgment where he acts in bad
faith, malice, revenge or some other similar motive.
• While respondent judge rendered adverse decisions against Antonio on the 3 cases filed before
the former, this does not lead to a conclusion that Judge Asis promulgated an unjust judgment.
b. Mere suspicion of partiality is not enough should there be adequate evidence to prove the charge.
• Respondent satisfactorily proved his decisions on the last 2 cases and petitioner failed to show
that the judge acted in fraud, dishonesty or corruption.