G.R. No. 254194 - Rosita vs. Zamora

On November 16, 1972, Primitivo Santos filed a sworn-letter complaint addressed to the then Secretary of Justice.
The complaint charged Municipal Judge Arturo E. Cruz, of the Municipal Court of Bulacan, with partiality and conduct unbecoming a judge by allegedly intervening with or preventing the filing of cases by the complainant.

The Secretary of Justice referred the complaint to Judge Cruz for his immediate comment.
On November 22, 1972, Judge Cruz submitted his reply, categorically denying the charges leveled against him.

The complaint was subsequently referred to the Executive District Judge of the Court of First Instance of Bulacan at Malolos for investigation, report, and recommendation.
District Judge Floreliana Castro-Bartolome, in her Report dated August 23, 1973, found that:

The allegations in the complaint were mainly based on the testimony and circumstantial evidence provided by Primitivo Santos.
A critical piece of evidence was the police blotter entry from June 1, 1972, which recounted an incident involving a complaint about slander and the alleged obstruction (closing of a door) at a commercial establishment.
The entry noted that although a statement was given to the officer’s chief, no further evidence showed that Judge Cruz was involved in obtaining or verifying the complainant's jurat.
Consequently, the failure in filing the necessary documents was attributed not to any action of Judge Cruz but to deficiencies on the part of the complainant.

In one incident, Primitivo Santos alleged he saw Judge Cruz entering the room during an investigation of a case against Teresita Cruz:

The allegation was based on an exchange where Teresita Cruz remarked, “Hindi totoo 'yan, nandyan sa labas si Judge Cruz.”
Santos interpreted this as evidence of interference, although it later emerged that the matter was resolved at the complainant’s instance.

The final paragraph of the letter-complaint cited a remark attributed to Judge Cruz: “BAKIT, UTUSAN MO BA KAMI RITO SA JUZGADO!”

However, there was no corroborative evidence to substantiate that these words were ever spoken by Judge Cruz.
The only admission was that the complainant signed the pleading on behalf of his lawyer, which did not directly implicate the judge.

During the formal investigation on February 9, 1973, Judge Cruz, while cross-examining witness Alberto T. Cano, lost his temper.
He is recorded as having said, “You can go to hell I don’t care or where do you want to go Mr. Cano,” a statement deemed unbecoming for a municipal judge.

The complainant sought that Judge Cruz voluntarily inhibit himself from handling Civil Case No. 250 and allow another judge to hear it.
In response, Judge Cruz suspended the proceedings in the said case.

Whether the complaint against Judge Cruz alleging partiality and interference in the filing of cases was sufficiently supported by evidence.

Did the evidence establish that Judge Cruz intentionally obstructed the filing process?
Was the complainant’s failure to obtain a signed jurat improperly attributed to Judge Cruz?

Whether the intemperate language used by Judge Cruz during the formal investigation constituted conduct unbecoming of a judge that merits administrative penalty.

Does the statement directed at witness Alberto T. Cano breach the expected decorum of judicial conduct?
Can a single instance of lose temper be grounds for administrative disciplinary measures?

The appropriate administrative sanction for a judge whose conduct, although not amounting to partiality, may nonetheless damage the image and integrity of the judiciary.