Facts:

The case revolves around an administrative complaint lodged by Pedro C. Abesa against Judge Jose P. Nacional, the presiding judge of the Municipal Trial Court (MTC) Branch 1 in Naga City. The complaint, filed on February 4, 2005, alleges conduct unbecoming of a judge. Pedro C. Abesa's son, Pedro Cornelio Jade Abesa, had died in a vehicular accident on December 6, 1999, prompting Abesa to file a criminal complaint for recklessness resulting in homicide against the driver, Hipolito Arlante. This case was assigned to Judge Nacional's sala. Abesa contends that during an ocular inspection of the accident scene on January 14, 2005, the judge summoned him and his wife to his chamber on January 19, without the presence of their counsel or the accused. During this meeting, Judge Nacional reportedly indicated a predisposition towards the accused's acquittal based on the weaknesses he perceived in the prosecution's case. He further urged Abesa to settle the matter, implying

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Facts:

Background of the Case

• Pedro C. Abesa, the complainant and father of the late Pedro Cornelio Jade Abesa, filed an administrative complaint against Judge Jose P. Nacional of the Municipal Trial Court (MTC) of Naga City, Branch 1.
• The complaint stemmed from the handling of a criminal case for reckless imprudence resulting in homicide involving Hipolito Arlante, the driver allegedly responsible for the vehicular accident that killed Abesa’s son.

Events Leading to the Complaint

• The criminal case was raffled to Branch 1 of the MTC, which was presided over by Judge Nacional.
• On January 14, 2005, an ocular inspection of the incident was conducted in the presence of counsels and parties involved.
• Subsequently, on January 19, 2005, Judge Nacional summoned the complainant and his wife to his chamber for a conference.

- a. Only the complainant and his wife were summoned; notably, no counsel or adverse party was present during this meeting. - b. During the session, Judge Nacional discussed the merits of the pending case, suggesting that the evidence was weak and that the likelihood of convicting the accused beyond reasonable doubt was minimal. - c. He added that the complainant’s son might have been at fault, thereby implying an acquittal for the accused.

The Judicial and Administrative Correspondence

• On April 7, 2005, Judge Nacional submitted a comment explaining his actions:

- a. He claimed his actions were based on both his professional evaluation of the case and personal empathy, noting that he too had lost a son in a vehicular accident. - b. He maintained that his evaluation of the evidence did not amount to a preconceived judgment but was a fair explanation of the legal standard of proof beyond reasonable doubt. - c. He asserted that his meeting with Abesa was carefully intended to enlighten the complainant about his options given the weak evidence. - a. He further justified the exclusion of the lawyers and the accused from the meeting by arguing that it was to avoid revealing that the complainant’s case was weak.

Proceedings and Administrative Resolution

• A resolution by the trial court on September 5, 2005, mandated that the parties manifest if they would submit the case for resolution based on the pleadings.
• Both parties eventually submitted their pleadings for resolution in subsequent correspondence (October 5, 2005, by the judge and October 20, 2005, by the complainant), with the latter attaching a decision from the Regional Trial Court (RTC) which had convicted the accused.
• The Office of the Court Administrator (OCA) evaluated the incident and recommended that Judge Nacional be found guilty of conduct prejudicial to the best interest of the service.

- a. The OCA emphasized that the in-chamber meeting with the complainant and his wife without counsel and the adverse party violated the ethical prohibition of in-chamber sessions. - b. It highlighted that the judge’s conduct compromised the appearance of impartiality required by the Code of Judicial Conduct.

Final Administrative Action

• The Court agreed with the factual findings and analysis by the OCA.
• Judge Jose P. Nacional was found guilty of conduct prejudicial to the best interest of the service.
• He was reprimanded and sternly warned that any repetition of similar acts in the future would be met with more severe disciplinary action.

Issue:

• Whether the act of summoning the complainant and his wife to the judge’s chamber without the presence of counsel and the adverse party constituted conduct unbecoming of a judge.
• Whether Judge Nacional’s actions, by discussing the merits of a pending case and suggesting settlement options, compromised the appearance of judicial impartiality and violated the Code of Judicial Conduct.
• Whether a personal claim of empathy (having also lost a son) could justify such an in-chamber discussion which might be perceived as bias or prejudgment of the case.
• Whether the conduct of a trial judge, regardless of noble intention, should be permitted when it risks eroding public trust and confidence in the integrity and impartiality of the judicial system.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)