The Supreme Court has dismissed the administrative complaint filed against Hon. Antonio Geoffrey H. Canja, Presiding Judge of the Municipal Trial Court of Polomolok, South Cotabato, for lack of merit. The Court found that the complaint, which accused the judge of gross ignorance of the law or procedure, was unmeritorious because the acts complained of pertained to his adjudicative functions and the complainant did not first exhaust available judicial remedies.
The Case
The case arose from Civil Case No. 22-804, which pertained to a three-hectare portion of a parcel of land with a total area of eight hectares located in South Cotabato, previously covered by Transfer Certificate of Title (TCT) No. T-331492.
On March 1, 2024, Judge Canja rendered a Decision partially ruling in favor of the plaintiffs, the Pamplona heirs. He directed defendants Loreto and Edith Dalisay (Spouses Dalisay) to execute a deed of reconveyance over Lot No. 2536-B-2, covered by TCT No. 145-2019002694, in favor of the plaintiffs.
On March 27, 2024, Spouses Dalisay filed an Ex-Parte Manifestation stating their counsel received the Decision on March 14, 2024. They said they were willing to abide by the ruling but asserted that the property to be reconveyed was not Lot No. 2536-B-2 but rather Lot No. 2536-B-3, covered by TCT No. 145-2019002695, which they occupied. On the same day, Judge Canja issued an Order treating the Ex-Parte Manifestation as a Motion for Reconsideration and set it for hearing.
The heirs of Pamplona filed a Vehement Opposition with Motion for the Issuance of a Writ of Execution, arguing that Judge Canja had no discretion to consider the Ex-Parte Manifestation as a motion and that the March 1, 2024 Decision had become final and executory. Judge Canja denied the motion for execution on May 14, 2024, holding the Decision had not attained finality. On May 16, 2024, he issued an Amended Decision dismissing Civil Case No. 22-804 for failure of the plaintiffs to prove their case by preponderance of evidence.
Pamplona then filed the administrative complaint, alleging gross ignorance of the law and incompetence, and that Judge Canja lost his temper and reversed a final Decision without a proper hearing. In his Verified Comment, Judge Canja maintained he acted in accordance with the applicable laws and evidence and denied losing his temper.
The Issue
The sole issue was whether Judge Canja is administratively liable for Gross Ignorance of the Law or Procedure when he motu proprio treated the Ex-Parte Manifestation as a motion for reconsideration, set Civil Case No. 22-804 for further hearing based thereon, and reversed the Decision dated March 1, 2024.
The Ruling
The Court found the complaint unmeritorious. It ruled that the acts complained of pertained to Judge Canja's adjudicative functions and that errors committed by a judge in the exercise of adjudicative functions cannot be corrected through administrative proceedings but should instead be assailed through available judicial remedies.
The Court's disposition reads: "ACCORDINGLY, the Administrative Complaint against respondent Hon. Antonio Geoffrey H. Canja, Presiding Judge of Municipal Trial Court, Polomolok, South Cotabato is DISMISSED for lack of merit. Consequently, the case is deemed CLOSED and TERMINATED."
By the Numbers
- A.M. No. MTJ-26-063 (Formerly JIB FPI No. 24-171-MTJ)
- Three-hectare portion of an eight-hectare parcel of land in South Cotabato
- TCT No. T-331492; Lot No. 2536-B-2 (TCT No. 145-2019002694); Lot No. 2536-B-3 (TCT No. 145-2019002695)
- Decision rendered: March 1, 2024
- Counsel received Decision: March 14, 2024
- Ex-Parte Manifestation filed: March 27, 2024
- Order denying writ of execution: May 14, 2024
- Amended Decision dismissing the case: May 16, 2024
- Report and Recommendation of the Judicial Integrity Office: October 21, 2025
- Fine recommended by the JIO: PHP 50,000.00
The Court's Reasoning
The Court explained that the filing of an administrative complaint is improper where adequate judicial remedies remain available, such as a motion for reconsideration, an appeal, or a petition for certiorari. Resort to and exhaustion of judicial remedies are pre-requisites for taking disciplinary measures against the judges concerned. Citing Governor Tallado v. Judge Racoma, the Court noted that if a judicial remedy is still available to the complainant, the administrative complaint shall be dismissed outright.
The Court said nothing in the Complaint demonstrated that Pamplona and his co-heirs had exhausted all judicial remedies available against the Amended Decision in Civil Case No. 22-804. It added that in the absence of fraud, dishonesty or corruption, the acts of a judge in his judicial capacity are not subject to disciplinary action, and there was nothing in the records showing that Judge Canja acted with ill motives or bad faith.
On the allegation that Judge Canja lost his temper, the Court reiterated that complainants must establish their claims by substantial evidence. It found Pamplona's bare allegation unsubstantiated, as the records did not show the judge acted with hostility toward Pamplona's counsel.
Source: Supreme Court Decision in A.M. No. MTJ-26-063 (Formerly JIB FPI No. 24-171-MTJ).
This report summarizes a public Supreme Court decision and is not legal advice.