REMEDIAL LAW | Villamor vs. Salas G.R. No. 101041, November 13, 1991

Villamor vs. Salas 

G.R. No. 101041, November 13, 1991


FACTS Judge Villamor dismissed five criminal cases filed by Carlos against Gloria Naval. He then issued an order of direct contempt against Carlos and his lawyer for supposedly using derogatory language. The Supreme Court annulled the contempt order. Carlos and his lawyer subsequently filed separate lawsuits against Judge Villamor for damages, claiming he knowingly rendered an unjust order of contempt. Judge Villamor filed motions to dismiss these lawsuits, arguing that other courts lacked jurisdiction. Whether Judges Aleonar and Salas can take cognizance of the lawsuits for damages filed against Judge Villamor for allegedly issuing an unjust order of contempt.


RULING NO. To allow respondent Judges Aleonar and Salas to proceed with the trial of the actions for damages against the petitioner, a co-equal judge of a co-equal court, would in effect permit a court to renew and interfere with the judgment of a co-equal court over which it has no appellate jurisdiction or power of review. The various branches of a Court of First Instance (now the Regional Trial Court) being co-equal, may not interfere with each other’s cases, judgments and orders (Parco v. Court of Appeals, 111 SCRA 262). This Court has already ruled that only after the Appellate Court, in a final judgment, has found that a trial judge’s errors were committed deliberately and in bad faith may a charge of knowingly rendering an unjust decision be levelled against the latter (Garcia v. Alconcel, 111 SCRA 178; Sta. Maria v. Ubay, 87 SCRA 179; Gahol v. Riodique, 64 SCRA 494). 


Here, the Supreme Court ruled that Judges Aleonar and Salas, as co-equal judges of Regional Trial Courts, cannot review the actions of another co-equal court. Only appellate courts have the authority to review and correct errors of trial courts. Additionally, the Supreme Court found no evidence that Judge Villamor acted with malice or wrongful intent in issuing the contempt order, which was ultimately an error in judgment. Therefore, he cannot be held liable for damages.








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