G.R. No. 34882 - Laput vs. Bernabe

On September 30, 2015, an anonymous resident of San Isidro, Siargao Island, wrote to the Office of the Ombudsman reporting that on September 29, 2015, Judge Exequil L. Dagala, presiding judge of the Municipal Circuit Trial Court of Dapa-Socorro, Dapa, Surigao del Norte, brandished an M-16 armalite rifle and shouted invectives during a boundary dispute and logging altercation. The complainant also alleged police inaction and rumors of the judge’s involvement in illegal drugs, fishing, gambling, logging, private army building, firearms possession, and maintaining mistresses.
The Ombudsman indorsed the letter to the Office of the Court Administrator (OCA) for appropriate action.

The OCA directed Executive Judge Victor A. Canoy of the Regional Trial Court of Surigao City to conduct a discreet inquiry. Judge Canoy’s January 29, 2016 report confirmed a boundary dispute and tree sale, noted an ongoing police probe into the firearm allegation, and recommended dismissal barring proof from the anonymous complainant.
The OCA also requested the National Bureau of Investigation (NBI) to investigate. The NBI’s February 11, 2016 report found that Judge Dagala:

Married Ms. “A” on July 18, 2006, with no issue in wedlock;
Fathered three children by different women on October 13, 2000, March 5, 2007, and March 24, 2008;
Had separated from his wife in 2008 and provided her P10,000 monthly support;
Was alleged connected to confiscated hardwood furniture, a cockpit business sale, and a court interpreter arrested in a drug bust.

By Indorsement dated April 25, 2016, the OCA furnished Judge Dagala copies of the anonymous letter, marriage certificate, and birth certificates, directing him to comment within ten days.
In his August 21, 2016 comment, Judge Dagala admitted marriage and paternity of three children, denied illegal logging and drug involvement, explained sale of his cockpit, and tendered an “irrevocable resignation” (rejected due to pending investigation).
On August 19, 2016, the OCA received by mail a USB containing a video of the September 29 incident. The PNP Firearms and Explosives Office later certified that Judge Dagala held no firearms license.

Whether an anonymous complaint supported by public records and respondent’s own admissions may sustain an administrative case under Rule 140.
Whether Judge Dagala was afforded sufficient notice and opportunity to explain his side (administrative due process).

Whether Judge Dagala’s act of brandishing an unregistered high-powered firearm during the altercation constitutes gross misconduct.
Whether his extramarital paternity during the subsistence of his marriage amounts to immorality warranting discipline.