Facts:

The case involves Administrative Matter No. RTJ-92-798, which was resolved by the Supreme Court En Banc on November 15, 2000. The complainant, Javier A. Ariosa, at the time the Provincial Governor of Zamboanga Del Sur, filed a sworn letter complaint on January 15, 1992, against Judge Camilo Tamin of the Regional Trial Court (RTC), Branch 23, in Molave, Zamboanga del Sur. The issue arose from the dismissal of two libel cases filed by Ariosa, identified as Criminal Case Nos. 91-10-212 and 91-10-213, entitled "People vs. Billy Yu, et al." Judge Tamin dismissed these cases based on the assertion that the RTC lacked jurisdiction, as the law specified that libel only warranted a punishment of arresto mayor or a fine of two thousand pesos, making it a matter for the Municipal Court under the local criminal procedure norms. Following the complaint, the Supreme Court instructed Judge Tamin to submit a comment, which he did on August 17, 1992, reiterating his position on jurisdi

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Facts:

Background of the Complaint

• Complainant: Javier Ariosa, then Provincial Governor of Zamboanga Del Sur, filed a sworn letter complaint on 15 January 1992.
• Nature of the Complaint: The complaint charged Judge Camilo Tamin with Gross Ignorance of the Law for dismissing libel cases based on a jurisdictional defect.
• Subject Cases: The complaint involved the dismissal of Criminal Case No. 91-10-212 and Criminal Case No. 91-10-213, both libel cases under the title “People vs. Billy Yu, et al.”
• Basis for Dismissal: Judge Tamin, in an Order dated 05 December 1991, reasoned that the Regional Trial Court (RTC) Branch 23 lacked jurisdiction because the crime of libel carried only the penalty of arresto mayor or a fine of P2,000.00 (or both).

Proceedings on the Administrative Complaint

• Response Initiated: On 02 June 1992, the Supreme Court directed Judge Tamin to file his Comment within ten days in response to the complaint.
• Judge’s Comment: On 17 August 1992, Judge Tamin filed his Comment arguing that the dismissal was proper, asserting that the RTC had no jurisdiction concerning the matter, and he invoked Article 357 of the Revised Penal Code to support his practice.
• Referral for Evaluation: On 03 September 1992, the Court referred the case to the Office of the Court Administrator (OCA) for evaluation, report, and recommendation.
• Initial Disciplinary Action: In a Memorandum dated 04 November 1992, the OCA recommended imposing a fine of P5,000.00 on Judge Tamin for ignorance of the law, a recommendation which was adopted by the Supreme Court in an En Banc Resolution dated 19 November 1992.

Subsequent Developments and Judicial Manifestations

• Motion for Reconsideration: On 11 January 1993, Judge Tamin filed a Motion for Reconsideration of the En Banc Resolution; he later requested its withdrawal in a Manifestation dated 07 December 1992.
• Manifestation of 17 May 2000:
• Judge Tamin assailed the En Banc Resolution of November 1992, alleging that the Supreme Court lacked constitutional jurisdiction over the case, rendering the decision null and void.
• He further contended that the Office of the Court Administrator had usurped the judicial appellate power, in violation of Presidential Decree No. 828 and the Constitution.
• In this Manifestation, he used highly intemperate and derogatory language against the Supreme Court, comparing the resolution to “a skull offering before the jurisprudential banquet of history.”

The Supreme Court’s Reaction and Final Disciplinary Action

• Review of the Manifestation: The Court, in an En Banc Resolution dated 08 August 2000, noted the intemperate language and instructed Judge Tamin to show cause regarding the undignified language employed.
• Judge’s Compliance: On 07 September 2000, Judge Tamin filed a Compliance in which he expressed remorse for his language, attributing it to a state of “deep depression and despair.”
• Disciplinary Findings and Sanction:
• The Supreme Court found that Judge Tamin’s conduct—his use of abrasive, intemperate, and undignified language—constituted a clear violation of the Canons of Judicial Ethics.
• Emphasizing the need to preserve the integrity and decorum of the judiciary, particularly the Supreme Court, the offending language was deemed incompatible with the high standards expected of a member of the Bench.
• Final Sanction: The Court imposed a fine of Twenty Thousand Pesos (P20,000.00) on Judge Tamin and issued a stern warning that any repetition of similar acts would be met with even harsher penalties.

Issue:

Jurisdictional and Procedural Validity

• Whether the dismissal of the libel cases by Judge Tamin on the basis of lack of jurisdiction was legally tenable.
• Whether invoking Article 357 of the Revised Penal Code sufficiently justified the dismissal despite the gravity of the complaint filed by the complainant.

Judicial Conduct and Use of Language

• Whether Judge Tamin’s use of intemperate, abrasive, and undignified language against the Supreme Court in his Manifestation violated the ethical standards and expected conduct of a judge.
• Whether such language could be considered as exceeding the bounds of permissible free expression and fair comment within the judicial system.

Appropriateness of the Disciplinary Measures

• Whether the imposition of a fine of P20,000.00 was commensurate with the violation committed by Judge Tamin.
• Whether the disciplinary proceedings and subsequent warnings were sufficient to uphold the integrity of the judiciary and deter similar misconduct in the future.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)