Facts:

The case at hand involves a complaint filed by Enriqueta Gargar de Julio against Judge Benjamin A.G. Vega on June 15, 1989, for conduct deemed unbecoming of a judge, jeopardizing public confidence in the judiciary. The events leading to this administrative case began in 1977 when Judge Vega and his wife, Carmelita Vega, leased a building owned by the complainant for a monthly rental of P500, operating a bake shop and hot pandesal business there. The lessees consistently defaulted on their rental payments starting July 16, 1977, despite repeated verbal demands from the owner. A formal demand letter was dispatched through counsel on November 25, 1977. This prompted the complainant to file an ejectment complaint in the Municipal Trial Court of Olongapo City on January 23, 1978, due to the non-payment of rent. The defendants contended that there were no dues owed after July 15, 1977, as they claimed to have ceased operations following Judge Vega's promotion to a higher court.

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Facts:

Parties and Transaction Background

• Complainant Enriqueta Gargar de Julio is the owner of a building located at No. 2706-A Rizal Avenue, Olongapo City, which she leased to Judge Benjamin A.G. Vega and his wife, Carmelita Vega.
• The lease involved a monthly rental of P500, and the Vegas operated a bake shop and hot pandesal business on the premises.

Rent Default and Legal Demands

• The lessees initially paid the rent regularly but defaulted starting July 16, 1977.
• The owner made verbal demands and subsequently sent a formal demand letter via counsel on November 25, 1977.

Ejectment Case and Judicial Proceedings

• On January 23, 1978, complainants filed an ejectment complaint in the Municipal Trial Court in Cities, Branch 1, Olongapo City (Civil Case No. 1690).
• Respondents (the Vegas) argued that no rents were due after July 15, 1977, claiming that they had ceased operations when Judge Vega was promoted to the Court of First Instance of Palawan.
• The case was marked by unusually long delays – a trial that lasted ten years – attributed primarily to Judge Vega’s dilatory tactics, including his taking the witness stand seven times and the rotation of four different presiding judges.

Judgment and Post-Judgment Developments

• Municipal Judge Emet B. Manalo rendered judgment on February 18, 1987, awarding the plaintiffs P2,500 (representing five months’ rental arrears from December 5, 1977, to April 5, 1978), plus legal interest and an attorney’s fee of P500.
• The total computed amount due, after interest over ten years and additional fees, reached P4,500.
• Judge Vega appealed the decision to the Regional Trial Court of Olongapo City, which affirmed the judgment, and his petition for review before the Court of Appeals was dismissed.

Execution and Administrative Case

• Despite the finality of the judgment, execution was delayed as Judge Vega questioned the computation of the amount due and attempted to divert service of the writ of execution to his residence.
• It was only after the complainant filed an administrative case against him on June 15, 1989, that Judge Vega paid the P4,500 through the Assistant Clerk of Court on July 21, 1989.

Judicial Conduct and Underlying Misconduct

• Judge Vega’s repeated delays, use of legal expertise, and multiple postponements exhibited oppressive conduct.
• His actions, seen as wilful failure to pay a just debt, raised serious concerns under Rule 140 of the Rules of Court and violated Rule 2.01, Canon 2 of the Code of Judicial Conduct, which mandates promoting public confidence in the judiciary.

Issue:

Abuse of Judicial Position

• Whether Judge Vega’s actions in delaying payment and manipulating legal procedures amounted to conduct unbecoming of a judge.
• Whether his use of dilatory tactics to evade a lawful obligation demonstrated a misuse of his legal knowledge and position.

Impact on Public Confidence and Judicial Integrity

• Whether the conduct of a judge, who deliberately obstructs the execution of a just decision for personal convenience, undermines public trust in the judiciary.
• Whether his behavior violates the explicit mandate to promote transparency and integrity as required by the Code of Judicial Conduct.

Adequacy of the Sanction Imposed

• Whether the imposition of a fine of P20,000 and a stern warning is sufficient to address the severity of the misconduct.
• Whether alternative penalties, such as expulsion from the bench (as argued in the concurring/dissenting opinion), should be considered given the circumstances.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)