Title
Fidel vs. Caraos
Case
A.M. No. MTJ-99-1224
Decision Date
Dec 12, 2002
Judge Caraos, allegedly drunk, demanded a prisoner's release at a police station, using offensive language. Found guilty of conduct unbecoming a judge, fined P5,000, and warned.
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Case Digest (A.M. No. MTJ-99-1224)

Facts:

  1. Incident at the Police Station

    • On February 29, 1996, at 10:45 PM, Judge Felix A. Caraos, allegedly heavily drunk, went to the Municipal Police Station of Candelaria, Quezon.
    • He attempted to forcibly release Natividad Braza, a detention prisoner charged with violating Article 151 of the Revised Penal Code, without a preliminary investigation or written order.
    • During the incident, Judge Caraos shouted invectives at the policemen on duty, including, "PUTANG INA NINYONG MGA PULIS KAYO, NASAAN SI HEPE? HOY, ILABAS NINYO ITO NGAYON DIN, PUTANG INA NINYONG MGA PULIS. SINONG MASUSUNOD DITO, MAYOR, PULIS, O JUDGE?"
  2. Complainant’s Allegations

    • P/SInsp. Omega Jireh D. Fidel, Chief of Police of Candelaria, Quezon, filed an Affidavit-Complaint charging Judge Caraos with Grave Abuse of Authority, Grave Misconduct, and Conduct Unbecoming of a Judge.
    • The complainant submitted joint affidavits from the policemen on duty and two detention prisoners who witnessed the incident.
  3. Respondent’s Defense

    • Judge Caraos claimed that earlier that day, at 5:30 PM, a group of market vendors approached him at a tennis court in Tiaong, Quezon, pleading for the temporary release of Natividad Braza.
    • After reviewing the case and finding it covered by the Rule on Summary Procedure, he agreed to help. He tried contacting the Chief of Police but failed. He then spoke to Police Officer Limbo, requesting Braza’s temporary release.
    • Later that evening, two men informed him that Braza was not released, prompting him to go to the police station. He admitted to being irritated by the policemen’s inattentiveness and uttered the words, "Bakit hindi ninyo sinasagot ang telepono? Putangina! Kailangan pa ba nating dagdagan yan? O alisin na dahil walang silbi, putangina! Paano na kung may emergency? O sunog? Nasaan na si Hepe?"
  4. Investigation Findings

    • Executive Judge Ricardo O. Rosales, Jr. found no evidence that Judge Caraos was intoxicated during the incident.
    • Judge Rosales recommended a reprimand with a stern warning against repetition of such conduct.
    • The Office of the Court Administrator (OCA) recommended a fine of P1,000.00 and a stern warning.

Issue:

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Ruling:

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Ratio:

  1. Judicial Conduct and Integrity

    • Judges are held to a higher standard of conduct, both in their official and personal lives. They must embody integrity, impartiality, and moral uprightness to maintain public confidence in the judiciary.
    • Judge Caraos’ actions, including his intemperate language and personal involvement in Braza’s release, fell short of the expected norms of judicial behavior.
  2. Temperance and Courtesy

    • Judges must always be temperate, patient, and courteous in their conduct and language, even outside the courtroom.
    • Judge Caraos’ use of offensive language and his display of irritation were inconsistent with the dignity and decorum required of a judge.
  3. Public Perception of the Judiciary

    • The judiciary’s credibility depends on the conduct of its members. Judges must avoid even the slightest appearance of impropriety.
    • Judge Caraos’ actions cast doubt on his impartiality and neutrality, undermining public trust in the judicial system.
  4. Accountability and Discipline

    • Judges are accountable for their actions, and any misconduct, regardless of intent, must be addressed to uphold the integrity of the judiciary.
    • The fine and stern warning imposed on Judge Caraos serve as a reminder of the heavy responsibility judges bear in maintaining the dignity of their office.


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