G.R. No. 154182 - Teves vs. Sandiganbayan

Antonio M. Lorenzana (Complainant), Executive Vice President and COO of Steel Corporation of the Philippines (SCP), then under corporate rehabilitation.
Judge Ma. Cecilia I. Austria (Respondent), presiding judge of RTC Branch 2, Batangas City, handling SP. Proc. No. 06-7993 (SCP rehabilitation petition).

January 21, 2008 Complaint: Alleged gross ignorance of law, grave abuse of authority, gross misconduct, grave incompetence, irregularity in duty, grave bias and partiality, lack of circumspection, conduct unbecoming of a judge, failure to observe reglementary period, and violation of the Code of Professional Responsibility based on:

Appointment of conflict-ridden rehabilitation receiver and adviser.
Informal “consultative” meetings outside jurisdiction dictating plan terms; secret communications with Equitable-PCI Bank (EPCIB).
Usurpation of receiver’s functions; off-record proceedings; refusal to subpoena witnesses; intimidation of SCP’s counsel.
Approval of modified rehabilitation plan beyond 180-day period without Supreme Court extension; erroneous interpretation of procedural rules.

April 14, 2008 Supplemental Complaint: Alleged impropriety under Code of Judicial Conduct (Canons 2.01–2.03) for maintaining a Friendster account with suggestive photos and personal details.

Office of the Court Administrator (OCA) referred complaints to respondent for comment.
Respondent submitted separate comments denying bad faith, asserting informal meetings were allowed, and defending her Friendster posts.
On September 9, 2009, the Supreme Court re-docketed the matter as an administrative case and designated the Court of Appeals (CA) for investigation.
Investigating Justice Gonzales-Sison conducted hearings and, in her January 4, 2010 Report and Recommendation, found partial merit:

Dismissed most charges as judicially correctible errors or unsubstantiated surmises.
Sustained conduct unbecoming (arrogance toward counsel) and impropriety (social-networking photos).
Noted grave ignorance of law in creating a management committee without evidentiary hearing.
Recommended P20,000 fine and admonition.

OCA’s September 4, 2013 Memorandum largely concurred, recommending noting the R&R and fining P20,000 with admonition.
On April 2, 2014, the Supreme Court rendered its final Decision.

Whether respondent committed gross ignorance of law, grave abuse of authority, grave incompetence, or irregularity by:

Whether respondent manifested grave bias, partiality, lack of circumspection, or conduct unbecoming of a judge by:

Holding off-record meetings outside jurisdiction and secret communications favoring EPCIB.
Intimidating and making snide remarks toward SCP’s counsel.

Whether respondent failed to observe the reglementary period prescribed by the Interim Rules on Corporate Rehabilitation.

Whether respondent violated the Code of Judicial Conduct by maintaining a public social-networking account with suggestive images (impropriety and appearance of impropriety).