Case Digest (Adm. Matter No. 2180-MJ)
Facts:
The case involves Municipal Judge Crisostomo Gonzales of Dingalan, Aurora, who faced administrative charges filed by Ephraim Mariano, along with two nurses, Doris Quinto and Ruth Roman. The events took place on September 21, 1977, when the complainants alleged that Judge Gonzales visited Mariano's home. Accompanied by his friends Nilo Buenconsejo, Jesse Querijero, Rogelio Bacani, and Sergio Gonzales, the judge invited Quinto and Roman to accompany them for a stroll along Dingalan Bay. When the nurses declined due to their prior commitments and the lateness of the hour, Judge Gonzales became upset, interpreting their refusal as an affront to his authority. He verbally berated the nurses, leading to a confrontation between himself and Mariano. In response to the complaint, Gonzales denied the claims of misconduct while admitting to the general allegations, albeit in an evasive manner. Specifically, he acknowledged inviting the nurses for a stroll and expressed his anger over
Case Digest (Adm. Matter No. 2180-MJ)
Facts:
- Background of the Case
- The case is an administrative proceeding filed against Municipal Judge Crisostomo Gonzales of Dingalan, Aurora, for conduct unbecoming of a judge.
- The complainants are Ephraim Mariano, a resident of Dingalan, Aurora, and two nurses, Doris Quinto and Ruth Roman, who were boarding in Mariano’s house.
- Incident Details
- On September 21, 1977, Judge Gonzales, accompanied by his friends Nilo Buenconsejo, Jesse Querijero, Rogelio Bacani, and Sergio Gonzales, visited the house of Ephraim Mariano.
- The judge invited the two nurses to accompany his friends for a stroll along the beach of Dingalan Bay.
- The nurses declined the invitation, citing that they were busy and noting that it was already late in the afternoon.
- Respondent’s Admission and Version of Events
- In his comment, Judge Gonzales acknowledged inviting the nurses “to have some fresh air along the beach of Dingalan Bay.”
- He admitted that the refusal of the nurses, which he attributed to a broken commitment by Ephraim Mariano, infuriated him.
- He stated that he, along with several male companions, went to Mariano’s house to confront him and the nurses, leading to a “discussion” during which:
- He “questioned” Mariano’s actions.
- An argument ensued, particularly with Doris Quinto, who was defending Mariano.
- He “admonished” Doris Quinto “in a manner she would understand,” suggesting a use of his position to enforce his personal will.
- Investigation and Hearing
- The case was referred to Executive Judge Ernesto B. Valencia of the Court of First Instance of Aurora for investigation.
- Although the complainants failed to testify during the scheduled hearings—largely due to not receiving the notices because of their change in residence—the evidence in the record was deemed sufficient.
- The Inquest Judge found that Judge Gonzales had attempted to impose his will on Mariano and the nurses to ingratiate himself with his companions, thereby violating judicial ethical standards, specifically Canon 34 of the Canons of Judicial Ethics.
- Findings Leading to Disciplinary Action
- The misconduct occurred within the municipality where the judge exercises his functions and even within the residence of the offended parties.
- The behavior of Judge Gonzales, notably his discourteous conduct and the misuse of his office for personal popularity, constituted conduct unbecoming of a judge.
Issues:
- Whether the actions of Municipal Judge Crisostomo Gonzales—specifically, his invitation to the nurses to join his companions on a beach stroll, his confrontation at Ephraim Mariano’s residence, and his subsequent admonishment of Doris Quinto—constituted conduct unbecoming of a judge.
- Whether the available record, despite the absence of the complainants’ testimony, was sufficient to sustain disciplinary action against the respondent.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)