Case Digest (A.M. No. P-13-3155) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Atty. Melvin D.C. Mane v. Judge Medel Arnaldo B. Belen, Atty. Mane, counsel for the plaintiff in Civil Case No. 3514-2003-C (“Rural Bank of Cabuyao, Inc. v. Samuel Malabanan, et al.”), filed a letter-complaint dated May 19, 2006 (received May 26, 2006) with the Office of the Court Administrator (OCA). He alleged that on February 27, 2006, during a hearing before Judge Belen of RTC Br. 36, Calamba City, the judge “demeaned, humiliated and berated” him by publicly questioning his competence on the basis of his alma mater and by subjecting him to intemperate, sarcastic, and personal remarks, as transcribed by the court stenographer. Atty. Mane also moved on April 24, 2006 for a copy of the tape recording of the proceedings, which went unacted upon, prompting his administrative complaint. Judge Belen, in his June 14, 2006 Comments, justified his conduct as a response to Atty. Mane’s December 15, 2005 motion to inhibit, which he claimed impugned his integrity, and to the motion fo... Case Digest (A.M. No. P-13-3155) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Filing of Complaint
- On May 19, 2006 (received May 26), Atty. Melvin D.C. Mane ("complainant") filed an administrative complaint against RTC Judge Medel Arnaldo B. Belen ("respondent"), Presiding Judge, Branch 36, Calamba City, alleging that during the February 27, 2006 hearing in Civil Case No. 3514-2003-C he had demeaned, humiliated, and berated him.
- Complainant submitted a stenographic transcript reflecting the following exchange (among others):
- Judge Belen asked if Mane was from UP Law, then stated “not all law students are created equal, not all law schools are created equal, not all lawyers are created equal.”
- Respondent’s Explanation and Counter-Assertions
- In his June 14, 2006 Comments, respondent asserted that an earlier “Urgent Motion to Inhibit” (filed Dec. 15, 2005) maliciously questioned his competence and integrity, justifying his orders (June 5, 2006) directing complainant to explain why he should not be cited for contempt.
- Respondent also explained that a pending unacted motion to furnish the tape recording of the hearing implied an unethical “editing” of the transcript, warranting his contempt orders.
- OCA Report and Supreme Court Proceedings
- Complainant withdrew his administrative complaint on September 4, 2006, but the Office of the Court Administrator (OCA) continued the investigation, finding no dispute over the accuracy of the transcript.
- The OCA Report (Nov. 7, 2007) concluded that Judge Belen’s insulting, demeaning, and intemperate language violated Canon 3 of the Code of Judicial Conduct, recommending a reprimand.
- This Court, by Resolution of Jan. 21, 2008, required submission on the basis of pleadings; respondent manifested compliance on Feb. 26, 2008.
Issues:
- Whether Judge Belen’s statements and conduct during the February 27, 2006 hearing constitute conduct unbecoming of a judge under the Code of Judicial Conduct (Canon 3).
- Whether the withdrawal of complainant’s administrative complaint bars the Court from proceeding with disciplinary action.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)