Case Digest (G.R. No. 239480)
Facts:
This administrative matter arises from an anonymous complaint dated January 15, 2014, against Judge Laarni N. Dajao, Presiding Judge of the Regional Trial Court, Branch 27, Siocon, Zamboanga del Norte. The complainant alleged that in the Order dated November 27, 2013, issued in Criminal Case Nos. 2013-08-05 (1049), 2013-08-06 (1050), and 2013-08-07 (1051) entitled People of the Philippines v. Julman Asim, Judge Dajao employed vulgar, intemperate, and malicious language—referring to a party as “big dick (penis),” “homophobic baklita,” “idiot,” “ugok,” and “psychopath”—and implied a sexual relationship between herself and the accused. The complaint also criticized her for appending the titles “Dr.” and “Ph.D.” next to her name, suggesting self-promotion and vainglory. In her Comment of May 6, 2014, Judge Dajao maintained that the complaint aimed only to malign her, noted that the underlying criminal cases had been dismissed without prejudice, and reported that she had accepted anCase Digest (G.R. No. 239480)
Facts:
- Nature of the complaint
- An anonymous letter-complaint dated January 15, 2014, accused Judge Laarni N. Dajao of:
- Manifesting a pattern of unprofessional conduct in language and deed during hearings.
- Styling herself as “Dr. Laarni N. Dajao, Ph.D (CL-HC)” in official orders.
- Making malicious and degrading statements in her Order dated November 27, 2013, in Criminal Cases Nos. 2013-08-05 (1049), 2013-08-06 (1050), and 2013-08-07 (1051), including references to “big dick/penis,” “homophobic baklita,” “idiot,” “ugok,” “psychopath,” and insinuations of a sexual relationship with the accused.
- The complaint prayed for Judge Dajao’s reprimand and discipline for unbecoming conduct.
- Judge’s comment (May 6, 2014)
- Maintained the complaint was aimed at maligning her.
- Stated the subject criminal cases were dismissed without prejudice, thus rendering the complaint moot.
- Noted she accepted an apology from the PDEA Regional Director on behalf of the operatives mentioned in the Order.
- Requested the complaint be dismissed.
- Office of the Court Administrator (OCA) report and recommendation (January 26, 2016)
- Found Judge Dajao administratively liable for vulgar and unbecoming conduct under Sections 1 and 2, Canon 4 of the New Code of Judicial Conduct.
- Noted the November 27, 2013 Order granted the defense’s omnibus motion to quash but contained intemperate language and an ostentatious use of titles (“Dr.” and “Ph.D.”).
- Recommended:
- Re-docketing as a regular administrative matter.
- Finding her liable and imposing a fine of Five Thousand Pesos (₱5,000.00) with a stern warning against repetition.
- Supreme Court resolution (March 2, 2020)
- Adopted the OCA’s findings and recommendation.
- Emphasized the judge’s language and self-promotion eroded public confidence in the judiciary.
- Imposed a fine of ₱5,000.00 with a severe warning that similar future acts will be dealt with more severely.
Issues:
- Whether Judge Dajao’s use of vulgar, intemperate language in her November 27, 2013 Order violated Sections 1 and 2, Canon 4 of the New Code of Judicial Conduct.
- Whether the inclusion of academic titles (“Dr.” and “Ph.D.”) in the Order constituted self-promotion and impropriety under Canon 2, Rule 2.02.
- What administrative sanction is appropriate for vulgar and unbecoming conduct as classified under Section 10(1), Rule 140 of the Revised Rules of Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)