A.M. No. RTJ-12-2326 - Beckett vs. Sarmiento, Jr.

Geoffrey Beckett filed a complaint against Judge Olegario R. Sarmiento, Jr. for gross ignorance of the law, manifest partiality, and neglect of duty.
The complaint arose from a custody dispute involving Beckett's son, Geoffrey Beckett, Jr., during the proceedings of Sp. Proc. No. 18182-CEB.
The case involved complex family dynamics, including previous legal battles between Beckett and his ex-wife, Eltesa Densing Beckett.

Geoffrey Beckett, an Australian national, was married to Eltesa Densing Beckett, a Filipina, with whom he had a son, Geoffrey, Jr., born on June 29, 2001.
The couple's relationship deteriorated, leading to legal disputes, including allegations of abuse and a declaration of nullity of their marriage.
A compromise agreement in 2006 granted Beckett full custody of Geoffrey, Jr., with visitation rights for Eltesa.

Beckett moved to Australia with Geoffrey, Jr., maintaining annual visits to Eltesa in Cebu.
In 2010, after allowing Geoffrey, Jr. to stay with Eltesa post-holidays, Beckett filed a petition for violation of RA 7610 when Eltesa did not return the child.
The case was assigned to Judge Sarmiento, who issued orders regarding custody and visitation.

Beckett accused Judge Sarmiento of issuing a March 15, 2011 order granting provisional custody to Eltesa, despite the prior compromise agreement.
Beckett claimed that Judge Sarmiento displayed bias by allowing Eltesa's friend into his chambers and conversing in Cebuano, which Beckett and his counsel did not understand.
Beckett's motions for reconsideration were allegedly ignored, leading to claims of dereliction of duty.

In response, Judge Sarmiento denied allegations of bias and maintained that his orders were proper, citing the need for a social case study report.
He argued that the custody decision was based on the welfare of Geoffrey, Jr., who expressed a preference to remain with his mother.
The judge asserted that he acted in good faith and had inhibited himself from further hearings in the case.

The OCA found merit in the charge of gross ignorance of the law, noting that Judge Sarmiento violated the principle of res judicata by granting provisional custody to Eltesa.
The OCA recommended that Judge Sarmiento be held liable for gross ignorance of the law but dismissed the charges of manifest partiality due to lack of substantial evidence.

The Court emphasized that gross ignorance of the law involves a significant lack of understanding of legal principles, which undermines public trust in the judiciary.
The Court disagreed with Beckett's assertion that Judge Sarmiento disregarded res judicata, stating that the judge prioritized the child's welfare in his custody decision.
The Court reiterated that custody arrangements are not permanent and can be adjusted based on the child's best interests.