Title
Jamin vs. De Castro
Case
A.M. No. MTJ-05-1616
Decision Date
Oct 17, 2007
A judge was dismissed and disqualified from re-employment for gross misconduct and immorality following a rape accusation by a waitress.
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Case Digest (A.M. No. MTJ-05-1616)

Facts:

  • Mary Jane Vallentos Jamin filed an administrative complaint against Judge Manuel A. de Castro of the Municipal Circuit Trial Court in Bohol.
  • The complaint arose from an alleged rape incident on March 29, 2005, when Jamin, a waitress, claimed Judge de Castro entered the bathroom without permission while she was changing clothes.
  • After serving Judge de Castro and his companions during a drinking session, he allegedly made unwanted advances, including inappropriate touching and kissing.
  • Jamin asserted that despite her protests, Judge de Castro forcibly took her to a storage area (bodega) where he raped her.
  • Co-worker Agnes Ybañez corroborated Jamin's account, stating she witnessed the judge dragging Jamin towards the bodega.
  • Judge de Castro denied the allegations, claiming they were a malicious attempt to damage his reputation and asserted he was only inspecting the bar.
  • He submitted affidavits of retraction from Jamin and Ybañez, claiming the charges were false.
  • The Bohol Provincial Prosecutor dismissed the criminal aspect of the complaint on October 27, 2005, without prejudice.
  • The Supreme Court later treated the matter as an administrative complaint and required Judge de Castro to respond.
  • The Office of the Court Administrator (OCA) found him guilty of gross misconduct and immorality, recommending his dismissal despite the retractions.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court found Judge Manuel A. de Castro guilty of gross misconduct and immorality.
  • The Court ruled that the affidavits of retraction ...(Unlock)

Ratio:

  • The Supreme Court emphasized that judges must uphold the highest standards of morality and decency, reflecting integrity in both their official and private lives.
  • Judge de Castro's actions, including sexual advances and inappropriate behavior in a public setting, were deemed unbecoming of a judge and violated the Code of Judicial Conduct.
  • The Cou...continue reading

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