Case Digest (A.M. No. MTJ-24-023)
Facts:
This case involves Tedwin T. Uy (complainant) who filed a Complaint-Affidavit against Hon. Jorge Emmanuel M. Lorredo (respondent), Presiding Judge of the Metropolitan Trial Court, Branch 26, Manila. The complaint accused Judge Lorredo of exhibiting partiality, conduct unbecoming of a judge, and irregularity in performing his official duties during criminal case hearings involving Tedwin as a co-accused. It was noted from the stenographer's notes that Judge Lorredo made significantly more comments (507) than both the prosecutor and defense counsel combined (totaling 356). Specifically, during the proceedings, Judge Lorredo asked Tedwin’s daughter, Trisha Uy, offensive and demeaning questions such as whether she was mentally retarded, under medication, or stupid. The judge also directed intimidating and disparaging remarks towards Tedwin's then lawyer, Atty. Erly Ecal, including questioning her competency and saying she was "kulang ang aral" (lacking education). Previously, JudgeCase Digest (A.M. No. MTJ-24-023)
Facts:
- Parties and Complaint
- Tedwin T. Uy (complainant) filed a complaint against Hon. Jorge Emmanuel M. Lorredo (respondent), Presiding Judge of Metropolitan Trial Court, Branch 26, Manila.
- The complaint charged Judge Lorredo with partiality in administering justice, conduct unbecoming of a judge, and irregularity in official duties.
- Allegations of Misconduct
- In a criminal case where Tedwin was a co-accused, Judge Lorredo was alleged to have actively and excessively participated in hearings.
- The stenographer's notes showed Judge Lorredo made 507 entries (questions, comments, manifestations) versus 356 entries by prosecutor and defense counsel combined.
- Judge Lorredo reportedly made harsh and demeaning comments directed at witnesses and counsel, including:
- Questioning Tedwin's daughter, Trisha Uy, if she was mentally retarded, under medication, or stupid.
- Making offensive, distasteful remarks damaging court integrity.
- Interrupting and intimidating Atty. Erly Ecal, Tedwin's lawyer, questioning her competence and education, including remarks that she was "kulang ang aral" (lacking education).
- Previous Administrative Liability
- Tedwin pointed out that Judge Lorredo had already been previously sanctioned for lack of judicial temperament and warned to avoid offensive language.
- Respondent’s Defense
- Judge Lorredo claimed these were questions necessary to uncover the truth.
- He justified asking Trisha Uy about mental deficiency to prevent later claims challenging her testimony.
- Report by Judicial Integrity Board
- The Board found Judge Lorredo guilty of unbecoming conduct for using inappropriate language.
- Recommended a PHP 10,000 fine and stern warning, noting:
- His active judicial participation was proper under the Judicial Affidavit Rule.
- However, words like "stupid," "mentally retarded," and "on medication" were offensive and unwarranted.
- The Board recognized prior sanctions for similar behavior and adjusted the fine accordingly.
- Prior Cases Involving Judge Lorredo
- Atty. Magno v. Judge Lorredo (2017) - found liable for unbecoming conduct, fined PHP 5,000 and stern warning given.
- Espejon v. Judge Lorredo (2019) - fined PHP 40,000 for simple misconduct (overbearing preliminary conference and religious remarks), PHP 10,000 for unbecoming conduct, and suspended 30 days for sexual harassment (derogatory comments on complainants’ sexual orientation).
- Prior sanctions totaled PHP 55,000 and suspension.
- Supreme Court's Observations and Decision
- Despite prior warnings and penalties, Judge Lorredo continued offensive conduct.
- Such repeated disregard undermines judicial integrity and demands dismissal to preserve public trust.
- Respondent violated multiple Canons (2, 3, 4, 5, and 6) of the New Code of Judicial Conduct.
- Separate counts of unbecoming conduct were found; dismissal and maximum fines recommended.
- Judge Lorredo was ordered dismissed with forfeiture of retirement benefits except accrued leave, perpetual disqualification from public office, and ordered to pay a PHP 175,000 fine for five counts of unbecoming conduct.
Issues:
- Whether respondent Judge Lorredo should be held administratively liable for partiality, conduct unbecoming of a judge, and irregularity in judicial duties.
- Whether the penalty imposed by the Judicial Integrity Board was sufficient given respondent’s repeated violations and prior administrative sanctions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)