Title
Supreme Court
Magno vs. Lorredo
Case
A.M. No. MTJ-17-1905
Decision Date
Aug 30, 2017
Judge Lorredo fined P5,000 for unbecoming conduct, including offensive remarks and lack of judicial decorum during a forcible entry case.

Case Digest (A.M. No. MTJ-17-1905)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Atty. Pablo B. Magno filed a verified complaint on March 6, 2013, charging Judge Jorge Emmanuel M. Lorredo of bias, partiality, arrogance, oppression, and violation of the Code of Judicial Conduct (CJC).
    • The complaint arose out of proceedings in a forcible entry/unlawful detainer case involving Que Fi Luan, Rodolfo Dimarucut, Teresa Alcober, and Teresita Dimarucut.
  • Chronology of the Proceedings
    • On March 3, 2010, Que Fi Luan, represented by Atty. Magno, initiated the case by filing a complaint for forcible entry against Rodolfo Dimarucut.
    • Due to Rodolfo’s death, Atty. Magno amended the complaint to seek an unlawful detainer remedy, impleading Teresa Alcober and Teresita Dimarucut.
    • On September 8, 2010, the Metropolitan Trial Court (MeTC), Branch 26, Manila, under Judge Lorredo, dismissed the complaint for Luan’s failure to appear for a mediation conference.
    • The Regional Trial Court (RTC) later reversed this dismissal on June 29, 2011, criticizing the premature dismissal without proper notification and remanding the case back to the MeTC for further proceedings.
  • Judicial Conduct and Proceedings in the Preliminary Conference
    • After the RTC decision became final, MeTC scheduled a preliminary conference.
    • Defendants’ counsel did not appear, and during the session, Judge Lorredo questioned Atty. Magno about his method of securing the favorable RTC decision.
    • Atty. Magno replied, “I never follow up on my cases.”
    • Following this exchange, Judge Lorredo exhibited anger by venting at Teresa’s husband, inquiring about the absence of their lawyer, and derogatorily remarking that their lawyer was “mahina” (weak).
    • Judge Lorredo further declared extemporaneously that he had effectively rendered a decision in the case that favored the opposing party, remarking that despite a favorable decision from him the RTC ruled against them.
  • Filing of Supplemental Complaint and Further Allegations
    • On August 14, 2013, Atty. Magno filed a Supplemental Complaint, adding further charges against Judge Lorredo which included:
      • Falsification of the minutes in the July 23, 2010 hearing by indicating a mediation conference set on August 4, 2010.
      • Not calling the cases at the prescribed time (8:30 a.m.).
      • Deviating from the centennial prayer mandated by the Court by reciting his usual prayer.
      • Failing to require personally delivering the order setting mediation to ensure proper notification.
      • Rendering an unjust and illegal decision in the case.
    • In his Comment to the Supplemental Complaint, Judge Lorredo denied all charges and disparaged Atty. Magno by describing him as “petty, dull and slow thinking” and went as far as to label him a “pathological or compulsive liar.”
  • Administrative Intervention and Evidence Presented
    • The Office of the Court Administrator (OCA) intervened, requiring Judge Lorredo to file his Comment within a set period through its 1st Indorsement.
    • To justify his actions, Judge Lorredo submitted copies of the Minutes from both the July 23, 2010 hearing and the preliminary conference, asserting that his conduct was part of a rational inquiry into inconsistencies regarding mediation scheduling.
    • Despite these submissions, Atty. Magno failed to present sufficient corroborative evidence to substantiate his allegations of judicial misconduct.
  • Judicial Principles and Precedents Cited
    • The case references the doctrine of the presumption of regularity in judicial acts, meaning that a judge’s actions are presumed lawful unless disproven by clear and convincing evidence.
    • Previous cases such as Magsucang v. Judge Balgos and Atty. Correa v. Judge Belen were cited to illustrate the necessity of maintaining judicial decorum and the high evidentiary standard required to rebut the judge’s presumption of regular performance.

Issues:

  • Whether Judge Lorredo’s conduct and language during the preliminary conference constituted a violation of the Code of Judicial Conduct and the Rules of Court.
    • Was his manner of questioning and use of derogatory language toward Atty. Magno and associated counsel an abuse of judicial discretion?
    • Did his actions mislead the parties by prematurely indicating the outcome of the case?
  • Whether the supplemental charges, including allegations of falsification of court records, failure to adhere to procedural protocols (such as timely case calling and mandated prayers), and improper notification methods, amounted to judicial misconduct warranting administrative sanctions.
    • Did Atty. Magno provide sufficient evidence to override the presumption of regularity of the judge’s official acts?
    • To what extent did Judge Lorredo’s conduct undermine public confidence in the judiciary?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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