Here’s a case digest about the Doctrine of Finality of Administrative Action. It’s the case of Almendra vs Judge Asis with A.M. No. RTJ-00-150 April 6, 2000.
Almendra vs Judge Asis
A.M. No. RTJ-00-150 April 6, 2000 | Doctrine of Finality of Administrative Action
Gaudencio Almendra was declared co-owner with the defendants in Civil Case No. 3773, an action for quieting of title, filed with respondent Judge. The decision was affirmed on appeal by the Court of Appeals and later became final and executory.
Subsequently, Thelma Almendra and Arthur Almendra, legitimate children of Gaudencio Almendra filed with the Regional Trial Court, Branch 10, Abuyog, Leyte an action for quieting of title with damages over Lot Nos. 4729 and 4731, naming Francisco, Vicente and Antonio Almendra and Jose Portillo as defendants. On March 29, 1996, Judge Enrique C. Asis declared Thelma and Arthur Almendra the rightful owners of Lot Nos. 4729 and 4731, recognizing their purchase of said lots as valid.
This prompted Almendra to file an administrative complaint dated July 30, 1996 against respondent judge alleging that respondents decision dated March 29, 1996 “grossly altered, modified and disobeyed the Final and Executory Decision of the Court of Appeals” which was promulgated September 30, 1982 involving the same parties and subject matter. Complainant contended that respondent judge caused “undue injury” through “manifest partiality, undue interest, evident bad faith or inexcusable negligence in failing to observe the doctrine of res judicata, in violation of par. (e) Section 3, Republic Act No. 3019, known as the Anti-Graft and Corrupt Practices Act.
Respondent judge filed his comment, alleging that his decision did not reverse a previous final decision but merely specified the division of the property in question.
Whether or not respondent judge should be liable for serious inefficiency in rendering the judgment in Civil Case No. 214 despite the existence of a final and executory judgment of the Court of Appeals
“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”
The decision rendered by respondent judge in Civil Case No. 214 and the decision of the Court of Appeals upholding the decision of the lower court in Civil Case No. 3773 clearly show that the issues, parties and subject matter are identical. Both cases are actions for quieting of title involving the same parcels of land. Plaintiff in Civil Case No. 3773 merely sold to his children, or his successors-in-interest, two portions of the subject property and the latter filed another case for quieting of title ruled upon in a previous final decision. Thus, respondent judge, in rendering decision in Civil Case No. 214, acted contrary to the doctrine of res judicata, the requisites of which are: (a) 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.
Since the decision rendered in Civil Case No. 3773 had reached finality, respondent should have refrained from hearing the merits of Civil Case No. 214, considering that the issues in the latter case had been settled in a previous judgment involving the same parties. A judge cannot amend a final decision, more so where the decision was promulgated by an appellate court. Judges should respect the orders, resolutions and decisions of higher courts, specially the highest court.