A.M. No. RTJ-99-1460, 99-7-273-RTC, RTJ-06-1988 - Office of the Court Administrator vs. Floro, Jr.

The Office of the Court Administrator (OCA) filed charges against Judge Florentino V. Floro, Jr. for mental unfitness to discharge the duties of his office as Judge of the Regional Trial Court (RTC), Branch 73, Malabon City.
Judge Floro was subjected to psychological and psychiatric evaluations by mental health professionals appointed by the Supreme Court.
Luz Arriego also filed a complaint (A.M. No. RTJ-06-1988) against Judge Floro, which was consolidated with the OCA’s administrative case.
Another case (A.M. No. RTJ-99-273-RTC) concerning a Resolution dated 11 May 1999 issued by Judge Floro was also consolidated.

Judge Florentino V. Floro, Jr. was fined Forty Thousand Pesos (P40,000.00) for seven of the thirteen charges against him in A.M. No. RTJ-99-1460.
He was relieved of his functions as RTC Judge and considered separated from service due to a medically disabling mental condition making him unfit for office, effective immediately.
By equity, he was awarded back salaries, allowances, and benefits corresponding to three years.
The complaint filed by Luz Arriego was dismissed for lack of merit.
The complaint regarding the May 1999 resolution was dismissed as moot.

Judge Floro filed three partial motions for reconsideration contesting the Court’s findings and penalties. His arguments included:

The Constitution mandates that incapacity of judges must be determined by a panel of impartial private medical specialists, and that the mental evaluations conducted by the Court’s appointed personnel were invalid and inadmissible.
The mental health professionals who prepared the evaluation reports were not properly presented during the administrative investigation, denying him the right to confront and cross-examine them, violating his due process rights.
The investigation and report by Retired Justice Pedro A. Ramirez ignored testimonies from Judge Floro’s ordinary witnesses (court officers, lawyers, neighbors, and a medical doctor) that affirmed his mental fitness, thus violating Rules of Evidence and due process.
The report excluded the testimony of a parapsychologist, Jaime T. Licauco, who supported Judge Floro’s claims regarding his mental state.

On 30 June 2006, Judge Floro further prayed for dismissal of the administrative complaint for lack of merit, full reinstatement, and award of back wages and benefits less the amounts he already received.

The Court denied all partial motions for reconsideration and supplements, finding no compelling reason to reverse its decision.
The Court emphasized judicial expectations of detachment and objectivity, and found that Judge Floro’s belief in “dwendes” (supernatural entities), combined with mental unfitness diagnosed by psychiatrists (including his own doctors during hearings), rendered him incapable of judicial functions.
The Court expressed concern that his condition would erode public trust and make the judiciary an object of ridicule.
The denial was final, and no more pleadings would be entertained.

Whether the Supreme Court erred in finding Judge Floro mentally unfit to hold office and in separating him from the service.
Whether the psychological/psychiatric evaluation reports by the Court’s appointed doctors were invalid due to defendants’ failure to be confronted and cross-examined.
Whether Judge Floro was denied due process during the administrative investigation, particularly the right to confront and cross-examine mental health professionals and to have all evidence considered.
Whether Judge Floro’s personal belief in supernatural entities (dwendes) is a valid basis for finding him mentally unfit and removing him from office.
Whether Judge Floro is entitled to reinstatement and back wages.