Title
Briones vs. Ante, Jr.
Case
A.M. No. MTJ-02-1411
Decision Date
Apr 11, 2002
A judge threw a chair at a court clerk, causing injury, and made inappropriate remarks, leading to a three-month suspension for grave misconduct and abuse of authority. Sexual harassment charges were dismissed.
Font Size:

Case Digest (A.M. No. MTJ-02-1411)

Facts:

  1. Complainant and Respondent:

    • Jocelyn T. Briones, a Clerk II of the Municipal Trial Court (MTC) of Sto. Domingo, Ilocos Sur, filed a complaint against Judge Francisco A. Ante, Jr., the presiding judge of the same court.
    • The complaint, docketed as OCA IPI No. 96-208-MTJ, alleged grave misconduct, acts unbecoming of a judge, oppression, and abuse of authority.
  2. Incident on September 3, 1996:

    • Complainant was instructed by the Clerk of Court, Apolonio T. Tagelo, to docket an order archiving a case.
    • Unable to find the docket book, she saw it in the possession of Court Interpreter Marcela Rabanal in the courtroom.
    • After retrieving the docket book, she placed it on a filing cabinet, but it fell, causing a loud noise.
    • Respondent judge appeared, shouted at her, and threw a monobloc chair at her, hitting her on the forehead and right arm.
    • Witnesses, including court stenographer Heraclea Soliven, corroborated the incident.
  3. Sexual Harassment Allegation:

    • On October 11, 1996, complainant filed another complaint (OCA IPI No. 96-229-MTJ) for sexual harassment.
    • She alleged that on March 13, 1996, during a staff snack, respondent told her someone was interested in her position but added, “I cannot give your job to that somebody because I plan to have you as my girlfriend first.”
    • Complainant claimed she was traumatized and cried after the incident.
  4. Respondent’s Defense:

    • Respondent denied hitting complainant with a chair and dismissed the sexual harassment claim as imaginary.
    • He alleged that the complaints were retaliatory, as he was about to file a complaint against complainant for falsifying her Daily Time Record.
  5. Investigation and Findings:

    • The case was assigned to Executive Judge Alipio V. Flores for investigation.
    • Judge Flores absolved respondent of the sexual harassment charge, finding the remark was made as a joke.
    • However, he found respondent guilty of grave misconduct, acts unbecoming of a judge, and abuse of authority, recommending a one-month suspension without pay.
    • The Office of the Court Administrator (OCA) adopted Judge Flores’ findings and recommendation.

Issue:

  1. Whether respondent judge is guilty of grave misconduct, acts unbecoming of a judge, and abuse of authority for throwing a chair at complainant and using intemperate language.
  2. Whether respondent judge is guilty of sexual harassment based on the alleged remarks made on March 13, 1996.
  3. What is the appropriate penalty for the offenses committed by respondent judge?

Ruling:

  1. Grave Misconduct, Acts Unbecoming of a Judge, and Abuse of Authority:

    • The Supreme Court found respondent judge guilty of these charges.
    • The testimonies of complainant and her witnesses were deemed credible, while respondent’s defense was insufficient.
    • The act of throwing a chair and using intemperate language violated Canons 2 and 3 of the Code of Judicial Conduct and the Canons of Judicial Ethics.
  2. Sexual Harassment:

    • The Court dismissed the sexual harassment charge, agreeing with the Investigating Judge that the remark was made as a joke and lacked malicious intent.
  3. Penalty:

    • The Court imposed a three-month suspension without pay, finding the recommended one-month suspension too lenient.
    • The Court emphasized that judges must uphold the highest standards of integrity and decorum.

Ratio:

  1. Judicial Conduct and Integrity:

    • Judges are held to the highest standards of conduct, both in their official duties and personal behavior.
    • Any act of impropriety, violence, or intemperate language undermines public confidence in the judiciary.
  2. Credibility of Witnesses:

    • The testimonies of complainant and her witnesses were consistent, straightforward, and credible.
    • Respondent’s defense, relying on his own testimony and that of his girlfriend (later wife), was insufficient to refute the allegations.
  3. Appropriate Penalty:

    • Violations of the Code of Judicial Conduct are classified as serious charges under Rule 140 of the Rules of Court.
    • The penalty of suspension for three months without pay is proportionate to the gravity of the offense, considering the need to maintain the integrity of the judiciary.
  4. Precedents:

    • The Court cited precedents where judges were penalized for similar acts of violence or misconduct, emphasizing the need for consistency in imposing penalties.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.