Case Digest (A.M. No. MTJ-17-1889)
Facts:
Re: Anonymous Complaint Against Presiding Judge Analie C. Aldea-Arocena, Municipal Trial Court in Cities, Branch 1, San Jose City, Nueva Ecija, A.M. No. MTJ-17-1889 [Formerly OCA IPI No. 16-2822-MTJ], September 03, 2019, Supreme Court En Banc, Per Curiam.The respondent is Judge Analie C. Aldea-Arocena, presiding judge of the MTCC, Branch 1, San Jose City, Nueva Ecija. The Office of the Court Administrator (OCA) received an anonymous complaint on July 3, 2014 alleging: (1) that Judge Arocena habitually conversed with litigants and prejudged cases and induced settlements; (2) that she urged accused persons to admit charges and discouraged appeals; (3) that she failed to inhibit in cases where her husband was a director of the plaintiff cooperative, and that she approved unconscionable compromise agreements; and (4) that she traveled abroad in March 2009 without obtaining required travel authority.
Pursuant to the OCA directive, Executive Judge Cynthia Martinez-Florendo of the RTC, San Jose City investigated and reported on November 4, 2014. Judge Florendo found substance to several allegations: that Judge Arocena encouraged settlements, that a lawyer alleged penalizing an accused under a law different from that charged (RA No. 3553 vs. Batas Pambansa Blg. 6), that Judge Arocena did not inhibit in two civil collection suits filed by Self-Reliant Team Primary Multi-Purpose Cooperative (Civil Case Nos. (09)3849 and (09)3851) in which her husband, Ferdinand D. Arocena, was a board member, and that compromise agreements approved by the judge reflected excessive interest and penalty rates shown in the promissory notes and statements of account.
The OCA required affidavits from interviewed persons. Some witnesses refused to execute affidavits for fear of reprisal; two defendants in the cooperative suits—Teresita M. Palma and Rowena C. Anicete—executed affidavits saying they did not sign or assent to the compromise amounts reflected in the MTCC decisions and were surprised at the ballooned balances. The Office of Administrative Services certified there was no record of a travel authority filed by Judge Arocena for March 2009. Judge Arocena submitted a Comment denying wrongdoing and asserting she secured travel permission and that the decisions were based on compromise agreements.
On October 19, 2016 the OCA issued a Memorandum: it found the allegations that Judge Arocena coerced settlements or induced guilty pleas unsubstantiated due to lack of sworn statements, but concluded that she violated Rule 137, Section 1 (failure to inhibit), Rule 3...(Pro-only)
Issues:
- In an administrative proceeding, were the allegations that Judge Arocena coerced settlements or induced guilty pleas sufficiently proven?
- Did Judge Arocena violate Section 1, Rule 137 of the Rules of Court and the impartiality/propriety canons of the 2004 New Code of Judicial Conduct by failing to inhibit in cases involving a cooperative where her husband was a director?
- Did Judge Arocena commit gross ignorance of the law or otherwise err by approving compromise agreements that incorporated excessive interest and penalty rates?
- Did Judge Arocena travel abroad in March 2009 without the required tra...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)