G.R. No. L-11311 - Ortega vs. Leonardo

In 1995, Florentino V. Floro, Jr. first applied for judgeship but a psychological evaluation by the Supreme Court Clinic revealed signs of ego disintegration and a developing psychotic process; he subsequently withdrew his application.
In June 1998, on reapplying, a new required psychological evaluation exposed further issues such as low self-esteem, mood swings, confusion, social/interpersonal deficits, paranoid ideations, suspiciousness, and perceptual distortions.
Despite these negative evaluations, his impressive academic background prompted the Judicial and Bar Council (JBC) to permit him to secure a second opinion from private practitioners, whose favorable report paved the way for his appointment as Regional Trial Court (RTC) Judge of Branch 73, Malabon City on November 4, 1998.

On March 2–3, 1999, at Judge Floro’s personal request, the Office of the Court Administrator (OCA) conducted an audit of his sala (courtroom/office).
The audit team, led by Atty. Mary Jane Dacarra-Buenaventura, reported various irregularities which were subsequently transmitted via a memorandum from Court Administrator Alfredo L. Benipayo to then Chief Justice Hilario G. Davide, Jr. on July 13, 1999.
Based on the audit findings, the Court en banc issued a resolution on July 20, 1999, which:

Docketed the administrative complaint as A.M. No. RTJ-99-1460.
Charged Judge Floro with 13 alleged acts or omissions ranging from self-aggrandizing conduct to procedural irregularities and violations of the Code of Judicial Conduct.
Directed Judge Floro to submit to an appropriate psychological or mental examination.
Placed him under preventive suspension pending the investigation.

Circulating self-laudatory calling cards and making self-promotional announcements in court, in violation of Canon 2, Rule 2.02 of the Code of Judicial Conduct.
Allowing his chambers to be used as sleeping quarters.
Rendering judicial resolutions without properly reduced written orders, in contravention of procedural rules (including Rule 36, Section 1, 1997 Rules of Procedure).
Displaying partiality in criminal cases and improper conduct during hearings, such as questioning custodians without the accused being sworn.
Involvement in personal cases, including allegedly signing pleadings in a civil habeas corpus case and appearing without leave in his private cases.
Making oral orders and subsequently revising them in a manner that deviated from standard procedure.
Using highly improper and intemperate language and openly criticizing judicial rules and the justice system.

A.M. No. RTJ-06-1988 – Involving allegations of misusing moral ascendancy to settle a criminal case in the guise of a civil settlement.
A.M. No. 99-7-273-RTC – Involving a resolution issued in connection with a petition for naturalization and the improper use of a case raffle procedure.

The 1995 SC Clinic evaluation noted serious mental concerns such as a developing psychotic process.
The June 1998 evaluation described symptoms like low self-esteem, mood swings, perceptual distortions, and social deficits.
Subsequent evaluations in connection with the administrative case (December 2000 and January 2001) reported findings of psychosis or delusional traits, including claims of psychic visions, the ability to be in a trance, and beliefs in supernatural phenomena.

Although some private evaluations suggested average intellectual functioning, the overall record revealed that his delusional beliefs and erratic behavior raised significant doubts about his mental stability and competency as a judge.

Following the issuance of the resolution for preventive suspension and investigation:

Judge Floro filed a verified comment, an “Answer/Compliance,” and several motions seeking dismissal or reconsideration of the administrative case.
He also filed separate administrative complaints against other judicial personnel and administrative officials, alleging collusion and misconduct against him.

The investigation, which ultimately consolidated several cases, prolonged his suspension. During this extended period, further evidence was gathered regarding both the serious misconduct in his actions and his mental and psychological unfitness to execute judicial duties.
The final administrative resolution addressed the 13 charges in connection with his conduct and his mental fitness, as well as the associated equitable considerations regarding his accrued benefits during suspension.

Whether Judge Floro’s display of self-laudatory conduct (circulating calling cards and making promotional announcements) constituted a violation of Canon 2, Rule 2.02 of the Code of Judicial Conduct.
Whether allowing the use of his chambers as a sleeping area and the lack of proper written resolutions constituted improper judicial conduct.

Whether his handling of cases—such as proceeding with hearings without the presence of the trial prosecutor and not issuing a written order for the release on recognizance—amounted to gross ignorance of the law and procedural negligence.
Whether his appearance in personal cases without prior authorization or leave of absence violated the prohibition against engaging in the private practice of law as mandated by Canon 5, Rule 5.07.

Whether Judge Floro’s alleged bias (“pro-accused” attitude) in criminal cases and his public statements undermined the impartiality required of a judge, thereby violating Canon 2, Rule 2.01.

Whether the findings of various psychological evaluations, which revealed delusional and psychotic features (such as claims of psychic powers, trances, and supernatural abilities), rendered him mentally unfit to discharge the functions of his judicial office.
Whether these mental health issues should serve as a basis for his removal from judicial service despite his academic and professional achievements.

How to balance the disciplinary penalty imposed on Judge Floro with the equitable award of back salaries, allowances, and benefits during his extended period of preventive suspension.
Whether his delay in procedural compliance and the filing of multiple related cases should affect the award of benefits in light of principles of equity.

Whether the charges in the second and third administrative cases (A.M. No. RTJ-06-1988 and A.M. No. 99-7-273-RTC) are moot or lack merit once his removal from judicial office is determined.