Case Digest (A.M. No. RTJ-15-2405)
Facts:
The case involves administrative complaints filed against Judge Jose S. Jacinto Jr., the Presiding Judge of the Regional Trial Court (RTC), Branch 45, in San Jose, Occidental Mindoro. The complainants, consisting of Antonio S. AscaAo Jr., Consolacion D. Dantes, Basilisa A. Obalo, Julieta D. Toledo, Joseph Z. Maac, Emiliano E. Lumboy, Tita F. Bernardo, Igmedio L. Noguera, Fidel S. Sarmiento Sr., Dan T. Taunan, Amalia G. Santos, Avelina M. Colonia, Eric S. Pastrana, and Marivel B. Ison, were section leaders of market stalls at the public market of the municipality. On June 26, 2012, they petitioned for prohibition against Mayor Jose T. Villarosa’s plan to demolish the public market, aiming to build a new commercial complex. This petition was filed as Special Civil Action No. R-1731 and assigned to Judge Jacinto's sala. The judge issued a 72-hour Temporary Restraining Order (TRO) on June 27, 2012, and hearings were set for July 2 and 3 of the same year. During the hearings, the
Case Digest (A.M. No. RTJ-15-2405)
Facts:
- The case is an administrative complaint filed against Judge Jose S. Jacinto, Jr. of RTC Branch 45, San Jose, Occidental Mindoro.
- The complaint charges the judge with gross and serious violations of the Canons of the Code of Judicial Conduct & Judicial Ethics and Section 3(e) of R.A. 3019 (Anti-Graft and Corrupt Practices Act).
Background of the Case
- Complainants: Antonio S. AscaAo, Jr., Consolacion D. Dantes, Basilisa A. Obalo, Julieta D. Toledo, Joseph Z. Maac, Fidel S. Sarmiento, Sr., Dan T. Taunan, Amalia G. Santos, Emiliano E. Lumboy, Tita F. Bernardo, Igmedio L. Noguera, Avelina M. Colonia, Eric S. Pastrana, and Marivel B. Ison, who were alleged to be section leaders of market stall lessees in the public market of Occidental Mindoro.
- Respondent: Judge Jose S. Jacinto, Jr.
- Adverse party background: Mayor Jose T. Villarosa of San Jose, Occidental Mindoro was involved because of his plan to demolish the public market to erect a new commercial complex.
Parties Involved
- On June 26, 2012, complainants filed a Petition for Prohibition with Urgent Application for a Temporary Restraining Order (TRO) and Writ of Preliminary Injunction (WPI) against the Municipality and Mayor Villarosa.
- The case was docketed as Special Civil Action No. R-1731 and assigned to proceed in a designated sala.
- On June 27, 2012, a TRO with a 72‑hour validity was issued by the respondent.
- Subsequent hearings were held on July 2 and July 3, 2012, regarding extension of the TRO and the issuance of a WPI against the Municipality.
- During the July 2, 2012 hearing, a discrepancy in courtroom access was noted: while the entire entourage of Mayor Villarosa was allowed entry, only 12 out of more than 500 members accompanying the complainants were permitted inside.
- Complainants were largely escorted out during proceedings, with the sole exception of Julieta D. Toledo who was slated to testify on that day.
Chronology and Court Proceedings
- Complainants alleged that respondent’s questioning of their witnesses was intentionally directed to discredit their opposition to the Mayor’s plan, insinuating the demolition was beneficial for municipal progress.
- It was further claimed that the judge not only denied proper access to the courtroom for complainant supporters but also conducted himself in a manner that was overly aggressive, berating, and confusing during testimony.
- Specific incidents included:
- The exclusion of most complainants during witness testimonies.
- Abrupt and unorthodox handling of courtroom procedures (e.g., allowing only one witness to remain during a critical testimony).
- Allowing Mayor Villarosa to exit the courtroom abruptly and later excusing his absence without prior clarification.
- Additional claims included that respondent demonstrated bias by appearing overly sympathetic or acting as an advocate for Mayor Villarosa.
- Complainants further asserted that prior cases before the respondent involving the Mayor or his allies were decided favorably to them, which supported claims of partiality.
Allegations Against the Judge
- Following the hearings, the respondent issued an open-court Order indicating the TRO would not be extended for an additional seventeen days and later lifted the TRO altogether.
- Complainants filed the formal administrative complaint citing multiple instances of judicial misconduct.
- In a Resolution dated November 25, 2013, the Supreme Court referred the complaint to the Presiding Justice of the Court of Appeals, Manila, for investigation, report, and recommendation.
- The report and recommendation were submitted by CA Justice Pedro B. Corales on June 9, 2014, and its findings were later adopted by the Supreme Court.
Post-hearing Developments and Investigation
Issue:
- Whether Judge Jacinto, Jr. acted in violation of the Canons of the Code of Judicial Conduct and Judicial Ethics by engaging in behavior that might suggest bias or partiality, including the exclusion of certain parties during hearings and the manner in which he questioned witnesses.
Violation of Judicial Conduct and Ethics
- Whether the judge’s conduct in handling the TRO, his interaction with complainants and witnesses, and his overall courtroom management constituted a gross violation of Section 3(e) of R.A. 3019.
Violation of the Anti-Graft and Corrupt Practices Act
- Whether the actions of the respondent, such as admitting only a limited number of complainant supporters into the courtroom and his subsequent remarks, undermined the required decorum and impartiality expected in judicial proceedings.
Procedural Fairness and Court Decorum
- Whether the evidence demonstrated a manifest partiality, gross inexcusable negligence, or an appearance of impropriety sufficient to warrant administrative sanctions against the judge under the prescribed judicial norms.
Determination of Appropriate Sanctions
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)