- Petitioner
- Rex G. Rico
- Respondent
- Marciana Q. Deguma
- Citation
- G.R. No. 211861
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Per Curiam
- Decided
- July 31, 2019
Summary
Rex Rico filed a civil case for damages against Judge Marciana Deguma under Articles 27 and 32 of the Civil Code, alleging the judge maliciously delayed resolution of proceedings in a criminal case where Rico was private complainant and wrongfully denied him access to court records. The Regional Trial Court dismissed the case, finding no cause of action. The Court of Appeals affirmed, ruling the judge did not act with malice or bad faith. The Supreme Court denied Rico's petition, holding that Article 27 covers only nonfeasance, not negligence in performance of duties, and that judges are exempt from Article 32 liability absent violations of penal statutes. The Court found the judge's actions were justified and reasonable, and that Rico's constitutional rights were not violated since the right to information is subject to reasonable regulation.