Case Digest (A.M. No. MTJ-22-007) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In A.M. No. MTJ-22-007 decided on March 9, 2022, complainants Marcelino Espejon and Erickson Cabonita filed a verified complaint against Hon. Jorge Emmanuel M. Lorredo, Presiding Judge of Branch 26, Metropolitan Trial Court, Manila. They alleged that during the preliminary conference of Civil Case No. M-MNL-18-08450-SC (an unlawful detainer action filed by Myrna Alcantara et al. against them), Judge Lorredo made remarks revealing his prejudgment of the case and displayed bias and partiality against them, repeatedly invoking his religious beliefs and disparaging homosexuality. The complainants moved for Judge Lorredo’s voluntary inhibition, which was denied, and subsequently appealed his adverse decision. They charged him with violations of Rule 1.02, Canon 1; Sections 1, 4, and 5 of Canon 3; and Sections 1 and 2 of Canon 5 of the New Code of Judicial Conduct. The Judicial Integrity Board (JIB) found that Judge Lorredo prejudged the merits, employed biblical passages to influence Case Digest (A.M. No. MTJ-22-007) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Complaint and underlying civil case
- On January 7, 2019, Marcelino Espejon and Erickson Cabonita filed a verified complaint against Judge Jorge Emmanuel M. Lorredo, Presiding Judge of MeTC Manila, Branch 26, alleging prejudgment, bias, and partiality in Civil Case No. M-MNL-18-08450-SC (unlawful detainer filed by Myrna Alcantara et al. against the complainants).
- They moved for the judge’s voluntary inhibition, which was denied, and subsequently appealed an unfavorable decision he issued in the ejectment case.
- Respondent’s defense
- Judge Lorredo denied any prejudgment or bias, explaining that he used Biblical teachings in settlement conferences and claimed to have settled over 100 cases using the Bible.
- He contended that his references to God’s punishment and homosexuality were warnings based on the transcript of stenographic notes (TSN) and the complainants’ own admissions about their tenancy.
- Judicial Integrity Board (JIB) evaluation
- The JIB found that Judge Lorredo virtually prejudged the ejectment case, improperly injected religious beliefs, and made irrelevant remarks about homosexuality, violating Canons 1, 3, and 5 of the New Code of Judicial Conduct.
- It recommended re-docketing the complaint as an administrative matter, finding grave misconduct and proposing a ₱40,000 fine with stern warning.
- Issue before the Supreme Court
- Whether Judge Lorredo should be held administratively liable and, if so, the proper classification of offenses and corresponding penalties.
Issues:
- Administrative liability
- Did Judge Lorredo commit violations of the New Code of Judicial Conduct and CSC Resolution No. 01-0940 through prejudgment, bias, overbearing conduct, and homophobic or religiously charged remarks during the preliminary conference?
- If so, do these violations constitute gross misconduct or lesser offenses (simple misconduct, conduct unbecoming, or work-related sexual harassment)?
- Standards and proof
- Application of Canons 2 (Integrity), 4 (Propriety), and 5 (Equality) of the New Code of Judicial Conduct.
- Requirements for proving bias or prejudice under administrative disciplinary rules and the need for extrinsic evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)