Case Digest (A.M. No. RTJ-10-2217)
Facts:
In Decena v. Malanyaon, petitioners Sonia C. Decena and Rey C. Decena lodged an administrative complaint dated April 10, 2007 before the Supreme Court via the Office of the Court Administrator, charging Hon. Nilo A. Malanyaon, Presiding Judge of RTC Branch 32 in Pili, Camarines Sur, with conduct unbecoming of a judge. The complaint arose from an administrative hearing conducted by Civil Service Commission Regional Office V on May 4, 2006 against Dr. Amelita C. Malanyaon, the judge’s wife, with their daughter, Atty. Ma. Kristina C. Malanyaon, as counsel. During that hearing, Judge Malanyaon sat at the counsel’s table, coached his daughter through written prompts, and even instructed questions designed to compel opposing counsel to produce his professional tax receipt. The hearing officer did not remove him but noted his conduct. Subsequent administrative proceedings before the Supreme Court’s Court Administrator saw Judge Malanyaon’s comment, medical episodes that rendered him meCase Digest (A.M. No. RTJ-10-2217)
Facts:
- Parties and Complaint
- Petitioners Sonia C. Decena and Rey C. Decena filed an administrative complaint dated April 10, 2007 against Hon. Nilo A. Malanyaon, Presiding Judge of RTC Branch 32, Pili, Camarines Sur, for conduct unbecoming a judge.
- The complaint arose from events during an administrative hearing on May 4, 2006 at the Civil Service Commission (CSC) Regional Office V, wherein Judge Malanyaon’s wife, Dr. Amelita C. Malanyaon, was the respondent and their daughter, Atty. Ma. Kristina C. Malanyaon, acted as counsel.
- Conduct at the CSC Hearing
- Judge Malanyaon sat at the counsel table beside his daughter and scribbled motions and questions for her, including demanding opposing counsel’s PTR number.
- When opposing counsel Atty. Zamora questioned his presence, he introduced himself as “the counsel of the respondent’s counsel,” snapped “And so what?!” and later apologized only after being admonished.
- Subsequent Administrative Proceedings
- Court Administrator Lock (June 21, 2007) required a comment; Judge Malanyaon filed one on July 15, 2007 denying unethical conduct, citing filial duty and lack of explicit prohibition.
- Court Administrator Elepaño (March 27, 2008) recommended re-docketing as a regular administrative matter, finding gross misconduct and a P50,000 fine.
- Multiple notices, motions to dismiss based on Judge’s stroke and mental incapacity, medical certifications, and procedural delays followed from 2009 to 2012.
- Court Administrator Marquez (February 6, 2012) reaffirmed the recommendation of gross misconduct and a P50,000 fine.
Issues:
- Whether Judge Malanyaon would be denied due process if the administrative case continued despite his medical incapacity.
- Whether Judge Malanyaon’s acts during the CSC hearing constituted conduct unbecoming of a judge.
- If guilty, what is the appropriate sanction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)