Facts:
P filed a criminal case against Judge X for knowingly rendering unjust judgment and malicious delay in the administration of justice before the Ombudsman. The Ombudsman referred the case to the Supreme Court for appropriate action. P assails the referral of the case to the Supreme Court arguing that the Ombudsman, not the Supreme Court, is the one vested with jurisdiction to resolve whether the crime charged was committed by the judge.
Issue:
Whether the referral of the case to the Supreme Court is correct
Held:
Yes. Before a civil or criminal action against a judge for a violation of Art. 204 and 205 can be entertained, there must first be “a final and authoritative judicial declaration” that the decision or order in question is indeed “unjust.” The pronouncement may result from either: (a) an action of certiorari or prohibition in a higher court impugning the validity of the judgment; or (b) an administrative proceeding in the Supreme Court against the judge precisely for promulgating an unjust judgment or order. Likewise, the determination of whether a judge has maliciously delayed the disposition of the case is also an exclusive judicial function.
