Case Digest (G.R. No. 215014)
Facts:
Tedwin T. Uy v. Presiding Judge Jorge Emmanuel M. Lorredo, Metropolitan Trial Court, Branch 26, Manila, A.M. No. MTJ-24-023 (Formerly OCA IPI No. 18-2966-MTJ), August 06, 2024, the Supreme Court En Banc, Per Curiam. The complainant is Tedwin T. Uy; the respondent is Hon. Jorge Emmanuel M. Lorredo, presiding judge of MTC Branch 26, Manila.
Tedwin filed a Complaint‑Affidavit alleging that Judge Lorredo displayed partiality, conduct unbecoming of a judge, and irregularity in performing his official duties during criminal proceedings in which Tedwin was a co-accused. The transcribed stenographic notes showed the judge made substantially more entries (507) — questions, comments and manifestations — than the prosecutor and defense counsel combined (356). Complainant described the judge’s interventions as adversarial, intimidating and oppressive.
Specific incidents alleged include the judge’s questioning of the complainant’s daughter, Trisha Uy, asking whether she was “mentally retarded, under medication, or downright stupid,” and persistent interruptions and demeaning remarks toward Tedwin’s counsel, Atty. Erly Ecal, including the comment that the lawyer was “kulang ang aral.” Tedwin also pointed to a prior administrative determination against Judge Lorredo for intemperate speech and admonishment to observe judicial temperament.
Judge Lorredo, in his Comment, defended his conduct as judicial questioning necessary to ascertain truth, explaining that his phrasing sought to preempt later claims that a witness’s mental state or medication affected testimony. The Judicial Integrity Board (JIB), in a July 6, 2022 Report submitted by Retired Justice Sesinando E. Villon and concurred in by three other retired justices, found him guilty of unbecoming conduct and recommended a fine of PHP 10,000 with a stern warning. The JIB recognized that the judge’s active participation in witness examination fell within judicial functions (noting the Judicial Affidavit Rule), but concluded that the language used — “stupid,” “mentally retarded,” and “on medication” — was unnecessary and inappropriate.
The Court noted Judge Lorredo’s administrative record: in Magno v. Lorredo (2017) he was fined PHP 5,000 for unbecoming conduct with a stern warning; in Espejon v. Lorredo (2022) he was sanctioned — fines totaling PHP 50,000 (PHP 40,000 for overbearing preliminary conference and improper religious comments, PHP 10,000 for unbecoming conduct) and suspended 30 days for sexual harassment. Those antecedent rulings, and prior admonitions that repetition would be dealt with more severely, were considered in this proceeding.
The sole stated questio...(Subscriber-Only)
Issues:
- Should respondent be held administratively liable for unbecoming conduct based on his recorded language and demeanor during court proceedings?
- If held liable, what disciplinary sanction is appropriate given respondent’s prior admini...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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