FACTS:

The case involves a series of legal actions between George Carlos and Judge Villamor. In 1977, a civil case was filed by Gloria Naval against Carlos for the ownership of a parcel of coconut land. The case was assigned to the sala of Judge Villamor. While the civil case was pending, Carlos filed criminal cases for qualified theft against Naval and her helpers, which were also assigned to Judge Villamor. Due to the pendency of the civil case, the criminal cases were temporarily archived. After trial, a decision was rendered in favor of Naval, declaring her the lawful owner of the land. Carlos moved to activate the archived criminal cases, but they were subsequently dismissed by Judge Villamor. A motion for execution pending appeal was also granted by Judge Villamor, prompting Carlos to file an administrative case against Judge Villamor. The administrative case was dismissed by the Supreme Court. Dissatisfied, Carlos filed a civil action for damages against Judge Villamor for knowingly rendering an unjust judgment in dismissing the criminal cases. In response, Judge Villamor issued an order of direct contempt against Carlos and his lawyer. Carlos filed a petition for certiorari with the Supreme Court to annul the contempt order. Judge Villamor's motion to dismiss the civil action for damages was granted, but Carlos and his lawyer separately filed complaints for damages against Judge Villamor. These complaints were assigned to different judges in the Regional Trial Court. Judge Aleonar denied Judge Villamor's motion to dismiss, and Judge Salas denied a motion to dismiss the separate complaint filed by Carlos. Judge Villamor filed a petition for certiorari and prohibition with the Supreme Court to stop the proceedings of the complaints for damages. The Supreme Court held that the Regional Trial Court judges had no jurisdiction to take cognizance of the actions for damages against Judge Villamor, as only higher appellate courts have authority to review and correct errors of trial courts. The Court emphasized that co-equal judges may not interfere with each other's cases, judgments, and orders. The Supreme Court also ruled that a judge is not liable for an erroneous decision unless there is malice or wrongful conduct in rendering it, which was not present in Judge Villamor's case. The petitions for certiorari were granted, and the cases were dismissed.

ISSUES:

1. Whether Judges Aleonar and Salas may take cognizance of the actions for damages against Judge Villamor for allegedly having rendered an unjust order of direct contempt.

2. Whether a judge can be held liable for an erroneous decision without malice or wrongful conduct.

RULING:

1. No. The Court held that Judges Aleonar and Salas may not proceed with the trial of the actions for damages against Judge Villamor. The principle that only the higher appellate courts have the authority to review and correct errors of trial courts applies. Allowing a co-equal court to interfere with the judgment of another co-equal court without appellate jurisdiction or power of review would be improper.

2. No. The Court ruled that a judge cannot be held liable for an erroneous decision in the absence of malice or wrongful conduct. In this case, there was no declaration that the erroneous order of direct contempt was rendered maliciously or with conscious and deliberate intent to commit an injustice. Therefore, Judge Villamor cannot be held criminally or civilly liable for the error of judgment.

PRINCIPLES:

• Only higher appellate courts have the authority to review and correct errors of trial courts.

• Co-equal courts may not interfere with each other's cases, judgments, and orders.

• A judge cannot be held liable for an erroneous decision without malice or wrongful conduct.