Case Digest (A.M. No. RTJ-99-1431)
Facts:
The case involves Judge Florentino M. Alumbres as the complainant and Judge Jose F. Caoibes, Jr. as the respondent. The incident occurred on May 20, 1997, outside the Staff Room of Branch 253 of the Regional Trial Court in Las Piñas City. Judge Caoibes had recently assumed office as the presiding judge of Branch 253, a newly created branch, and had the authority to recommend employees for appointment. Judge Alumbres, who was the executive judge at the time, sought to secure a position for his son in Branch 253. Initially, Caoibes agreed to recommend Alumbres' son for the position of utility man, and later for the position of process server. However, the Court Administrator found the endorsement inappropriate due to nepotism concerns, leading to Alumbres' son not being appointed.
After Alumbres was replaced as executive judge, he requested his successor, Judge Bonifacio Sanz Maceda, to endorse his son's appointment again. This time, Caoibes withdrew his recommend...
Case Digest (A.M. No. RTJ-99-1431)
Facts:
Background of the Case
- Judge Florentino M. Alumbres (complainant) and Judge Jose F. Caoibes, Jr. (respondent) were both members of the Judiciary, serving as Presiding Judges of Branches 255 and 253, respectively, of the Regional Trial Court of Las Piñas City.
- The incident in question occurred on May 20, 1997, outside the Staff Room of Branch 253, in plain view of several lawyers and litigants.
Employment of Alumbres' Son
- Branch 253 was a newly created court, and Judge Caoibes had the privilege of recommending employees for appointment.
- Judge Alumbres sought to secure employment for his son, initially proposing him as a utility man and later as a process server for Branch 253.
- Judge Caoibes initially agreed to recommend Alumbres' son but later withdrew his recommendation, opting instead to recommend David Cariño for the position.
Dispute Over a Borrowed Table
- Judge Alumbres lent an executive table to Judge Caoibes for temporary use while awaiting the delivery of office furniture.
- On May 20, 1997, Alumbres sent his deputy sheriff to reclaim the table, but Caoibes refused, stating he would continue using it until his furniture arrived.
- Alumbres, accompanied by his process server and deputy sheriff, went to Caoibes' chambers to retrieve the table. Caoibes was not present, so Alumbres waited in the hallway.
The Altercation
- Upon being informed of Alumbres' presence, Caoibes approached him. A verbal exchange ensued, during which Alumbres forcefully jerked Caoibes' wrist.
- Caoibes reacted by shouting "Tarantado ito, ah," and delivered two punches: one to Alumbres' right temple and another to his left jaw.
- The incident was witnessed by lawyers, litigants, and court personnel. Judge Bonifacio Sanz Maceda intervened to prevent further escalation.
Medical Findings
- Alumbres sustained minor injuries, including a swollen chin with a 1 cm laceration and a pinhead-sized laceration on his right temple.
Defense of Judge Caoibes
- Caoibes denied intentionally punching Alumbres, claiming his actions were instinctive and occurred while struggling to free himself from Alumbres' grip.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Judicial Conduct and Integrity:
- Judges are held to the highest standards of integrity and propriety. Their conduct, both official and personal, must inspire public confidence in the judiciary.
- Canon 2 of the Code of Judicial Conduct mandates that judges avoid impropriety and the appearance of impropriety in all activities.
Violation of Judicial Standards:
- Judge Caoibes' use of physical violence against a fellow judge, especially within court premises and during office hours, violated the Code of Judicial Conduct.
- Such behavior undermines the dignity and sanctity of the judiciary and erodes public trust.
Provocation as a Mitigating Factor:
- While Judge Alumbres provoked the incident by forcefully jerking Caoibes' wrist, this does not justify Caoibes' violent reaction.
- Judges are expected to exercise self-restraint and judicial temperament, even in the face of provocation.
Penalty Imposed:
- The Court tempered the penalty due to the provocation by Alumbres, imposing a fine instead of suspension or dismissal.
- The fine serves as a reminder of the gravity of the offense while acknowledging the mitigating circumstances.
Public Perception of the Judiciary:
- The incident, which occurred in full view of lawyers and litigants, tarnished the image of the judiciary.
- Judges must avoid behavior that diminishes the public's respect for the courts and the administration of justice.