Case Digest (A.M. No. RTJ-08-2139)
Facts:
The case involves an administrative complaint filed by Michael B. Belen against Judge Medel Arnaldo B. Belen, the Presiding Judge of the Regional Trial Court (RTC) of Calamba City, Branch 36. The complaint, dated March 7, 2001, was lodged with the Office of the Court Administrator (OCA) and accused the respondent judge of grave abuse of authority and conduct unbecoming a judge. The events leading to the complaint began in March 2004 when Judge Belen filed an estafa case against Michael's father, Nezer D. Belen. This case was dismissed for lack of probable cause by Assistant City Prosecutor Ma. Victoria Sunega-Lagman on July 28, 2004. Following the dismissal, Judge Belen filed an Omnibus Motion for Reconsideration and Disqualification against Sunega-Lagman, alleging her frequent absences during preliminary investigations. In response, Michael B. Belen executed an affidavit on May 19, 2006, refuting the judge's claims and asserting that it was Judge Belen who was absent...
Case Digest (A.M. No. RTJ-08-2139)
Facts:
Background of the Complaint
- Complainant Michael B. Belen filed an administrative complaint against Judge Medel Arnaldo B. Belen, Presiding Judge of the Regional Trial Court (RTC) of Calamba City, Branch 36, for grave abuse of authority and conduct unbecoming a judge.
- The complaint stemmed from a series of actions taken by Judge Belen against Michael Belen and his family, allegedly in retaliation for Michael’s affidavit supporting Assistant City Prosecutor Ma. Victoria Sunega-Lagman in a disciplinary case filed by Judge Belen.
Estafa Case Against Complainant’s Father
- In March 2004, Judge Belen filed an estafa case against Michael Belen’s father, Nezer D. Belen. The case was dismissed for lack of probable cause by Assistant City Prosecutor Sunega-Lagman.
- Judge Belen filed an Omnibus Motion for Reconsideration and Disqualification, alleging Sunega-Lagman’s absence during preliminary investigation hearings. He also filed a disciplinary complaint against her with the Integrated Bar of the Philippines (IBP).
Complainant’s Affidavit and Retaliation
- Michael Belen executed an affidavit in May 2006, refuting Judge Belen’s allegations against Sunega-Lagman. The affidavit stated that Sunega-Lagman was present during the hearings and that it was Judge Belen who was absent.
- Following this, Judge Belen allegedly began harassing Michael Belen, threatening to file multiple cases against him.
Inspection of Complainant’s Piggery
- On January 11, 2007, Judge Belen, accompanied by local officials, inspected Michael Belen’s piggery and poultry business. He took pictures and sent text messages to Michael, who rushed to the scene.
Letters to Local Government Authorities
- Judge Belen wrote several letters to local government officials, including the Municipal Engineer and Mayor of Alaminos, Laguna, requesting information about Michael Belen’s business and alleging violations of the National Building Code and environmental laws.
- The letters bore a letterhead indicating Judge Belen’s judicial position, stating they were “from the chambers of” the Presiding Judge of RTC Calamba City, Branch 36.
Criminal Case Filed by Judge Belen
- Judge Belen filed a criminal case against Michael Belen for violations of environmental laws, docketed as I.S. No. 07-246/07-247.
Judge Belen’s Defense
- In his comment, Judge Belen claimed he acted as a private citizen and landowner, not as a judge, and that he used his personal stationery, not the court’s official letterhead.
Issue:
- Whether Judge Medel Arnaldo B. Belen violated the New Code of Judicial Conduct for the Philippine Judiciary by using his judicial position to advance his personal interests.
- Whether Judge Belen’s actions, including the letters and criminal case, constituted grave abuse of authority and conduct unbecoming a judge.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)