Facts:

This case involves an administrative complaint filed by Elizabeth Alejandro, Romeo C. Alejandro, Lilia P. Seroma, and Francisco Seroma against Hon. Sergio A. Plan, the Presiding Judge of the Municipal Trial Court of Cauayan, Isabela, Philippines. The complaint was initiated in May 1999, as the complainants were facing criminal charges in Cases No. 97-3610 and 3611, entitled "People of the Philippines vs. Romeo Alejandro, et al.," for grave oral defamation and malicious mischief, pending before Judge Plan. The complainants alleged that during court hearings, the judge exhibited partiality by engaging in friendly conversations with Simon Aquino, who was the complaining witness in their case, while treating the accused dismissively and rudely. The situation escalated during one instance when the respondent postponed a hearing and, upon inquiry from the complainants, sarcastically replied that they should consult their counsel instead of engaging with him. There were furth

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Facts:

Background of the Complaint

• In May 1999, the complainants—Elizabeth Alejandro, Romeo C. Alejandro, Lilia P. Seroma, and Francisco Seroma—filed an administrative complaint against respondent Judge Sergio A. Plan, then presiding over the Municipal Trial Court of Cauayan, Isabela, alleging partiality and acts unbecoming of a judge.
• The complaint arose during criminal cases (Case Nos. 97-3610 & 3611, “People of the Philippines vs. Romeo Alejandro, et al.”) wherein the complainants were accused for grave oral defamation and malicious mischief.

Allegations of Judicial Misconduct

• The complainants alleged that at each hearing, respondent Judge Plan was seen conversing pleasantly with Simon Aquino, the complaining witness in the criminal case, inside his chambers.
• It was further claimed that when the scheduled hearings were postponed, the judge responded sarcastically and rudely to the complainants, stating, “What do I care. You ask your counsel,” followed by a command to “Do not talk to me!”
• The judge was further accused of attempting to persuade the complainants to surrender the land in dispute—allegedly claimed by Simon Aquino—in exchange for Aquino’s withdrawal of the criminal cases against them.
• When the complainants refused, respondent Judge Plan allegedly threatened to delay the resolution of their case.

Testimonies and Evidence Presented

• Complainant Testimonies
• Romeo Alejandro testified about witnessing Simon Aquino leaving Judge Plan’s chambers after hearings, the repeated postponement of their case, and the judge’s rude dismissal when questioned for the reason behind such delays.
• Romeo recounted observing an instance where Aquino delivered an ice chest containing fresh fish (purportedly a bribe) to the court staff during a Christmas party at the judge’s office.
• Additionally, he stated that the judge personally directed him and his co-accused to concede the land claim in order to resolve their pending case, raising his voice when they refused.
• Elizabeth Alejandro testified that in 1998, during an encounter where she approached the judge about Aquino’s alleged inquiry with the governor concerning the case, the judge responded by yelling at her and branding her a liar. She also corroborated the claim that Judge Plan attempted twice to convince them to yield to Aquino’s demands by threatening delays in resolving their case.

Administrative Proceedings and Resolution

• While the case was pending, respondent Judge Plan opted for retirement on September 13, 1999.
• On February 9, 2000, the Court referred the matter to Executive Judge Henedino P. Eduarte of the Regional Trial Court, Cauayan, Isabela, for investigation, report, and recommendation.
• Judge Eduarte conducted hearings on April 26 and 27, 2000, and subsequently, on June 16, 2000, submitted his report recommending that respondent Judge Plan be fined P2,000.00 for using intemperate language and fraternizing with litigants.
• The Office of the Court Administrator later affirmed this recommendation through its memorandum on August 23, 2000.
• Additional administrative proceedings included the release of a portion of the judge’s retirement benefits pending the resolution of related administrative cases, with P50,000.00 retained as a contingent measure.

Issue:

Whether respondent Judge Plan engaged in acts of judicial misconduct by:

• Exhibiting preferential treatment toward Simon Aquino, a complaining witness in a pending criminal case.
• Using rebuttal language and behavior that suggested partiality—evidenced by sarcastic and rude responses to the complainants.
• Attempting to influence the outcome of litigation by pressuring the complainants to surrender interests in disputed property.
• Creating an appearance of impropriety that could undermine the public confidence in the impartial administration of justice.

• Whether the allegations of misconduct were substantiated by the evidence and testimonies, particularly when compared with the conflicting version presented by respondent Judge Plan.

• Whether the judge’s conduct violated the Code of Judicial Conduct, especially the provisions related to maintaining the appearance of impartiality and avoiding behaviors that could be construed as improper even if not intrinsically unethical.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)