A.M. RTJ-20-2600 - Obiedo vs. Santos, Jr.

Complainant Roberto L. Obiedo had previously filed an Estafa case against the Nery Spouses (Nino Rico and Mary Anne Nery).
The case, docketed as Criminal Case No. 2012-0426, was raffled to respondent Judge Soliman M. Santos, Jr.’s sala.
After trial on the merits, on 17 December 2018, the respondent Judge rendered a decision acquitting the Nery Spouses criminally while holding them civilly liable to Obiedo for actual and moral damages aggregating to P1,390,000.00, subject to interest.

Subsequent to the promulgation of his decision, respondent Judge sent a text message to the counsels of the parties involved.
The text message, written in a colloquial and abbreviated style, attempted to explain and justify his ruling.
Specific statements in the message indicated:

His preference for a “more practical” mechanism rather than an appeals process.
A suggestion that the ruling be perceived as better or more acceptable through alternative means rather than letting the judgment solely speak for itself.
A reference to not making “hometown decisions,” which implied a perceived bias against Naga City residents such as Obiedo.

On 11 June 2019, Obiedo, through counsel, filed a Verified Complaint before the appropriate court.
Obiedo alleged that the text message constituted a gross violation of the Code of Judicial Conduct and was an act of gross ignorance of the law.
The complaint asserted that:

The extra-judicial communication was improper as it unduly commented on and attempted to justify his judgment.
By disappearing into explanations outside the formal judgment, the Judge gave the impression of uncertainty regarding his decision, thereby potentially influencing the parties regarding motions or appeals.
There was an appearance of bias given the mention of “hometown decisions,” suggesting partiality against Naga City litigants.

It was noted that respondent Judge had earlier administrative cases where he was penalized:

In Susan R. Elgar v. Judge Soliman M. Santos, Jr. – found guilty of violations including improper conduct in communicating with counsel, leading to multiple fines totaling Php100,000.00.
In Peter U. Borromeo v. Judge Soliman M. Santos, Jr. – found guilty of gross misconduct and admonished with a stern warning.

The respondent Judge’s repeated offenses were instrumental in the analysis of his conduct in the present case.

In its Report dated 04 September 2020, the OCA found respondent Judge liable for impropriety in sending the text message, which was deemed “highly inappropriate” as it was not part of the judicial proceedings.
The OCA emphasized that the text message cast doubt on the Judge's integrity, impartiality, and competence.
The Report recommended:

Re-docketing the administrative complaint as a regular administrative matter.
Finding the respondent Judge guilty of impropriety.
Imposing a fine of Php20,000.00 and cautioning him to be more circumspect in the future.

Whether or not respondent Judge Soliman M. Santos, Jr. is administratively liable for the alleged violations of the Code of Judicial Conduct arising from his post-judgment text message.

Does the sending of the text message, which sought to justify and explain his ruling, constitute a breach of judicial propriety?
Can such behavior be held as a violation of the specific provisions of the Code of Judicial Conduct, particularly regarding the avoidance of impropriety and the appearance thereof?
How should the repeated prior administrative offenses influence the imposition of a penalty in the present case?