Case Summary (G.R. No. L-27152)
Procedural Background
The complaint was filed on September 19, 1995, accompanied by a sworn statement detailing alleged sexual misconduct by Judge Lustre. The chronology of events includes various hearings that the complainant claims were manipulated by Judge Lustre to delay the proceedings, resulting in a series of personal encounters that Liwanag asserts were not consensual.
Allegations of Misconduct
Liwanag's allegations detail instances of inappropriate conduct by Judge Lustre, including unwanted touching and demands for sexual acts under the threat of adverse repercussions for her legal case. Throughout the documented encounters, she claims that Judge Lustre leveraged his position to coerce her into sexual activity, citing examples of scheduled meetings that turned into occasions for sexual misconduct.
Respondent's Defense
Judge Lustre denied the allegations, attributing them to Liwanag's supposed malice stemming from his refusal to expedite the B.P. 22 cases in favor of her husband. He claimed that he could not have engaged in the alleged immoral acts due to health conditions associated with his age and medical issues. Various affidavits and certifications were presented by Lustre to establish his character and refute the claims made against him, including an assertion that he could not have participated in sexual acts due to his physical ailments.
Investigation and Findings
The investigation into the allegations involved a referral to Judge Norberto Geraldez for an objective inquiry, which ultimately recommended the dismissal of the complaint, citing a lack of evidence to support Liwanag’s claims. This recommendation was met with dissent from the Office of the Court Administrator (OCA), which found the allegations credible and called for severe consequences against Lustre.
Standards for Administrative Cases
The Court found that the standard of proof in administrative cases is based on substantial evidence rather than proof beyond a reasonable doubt. This distinction is critical in assessing Liwanag’s claims, which the Court ultimately deemed sufficiently credible to warrant action against Lustre.
Evaluating the Evidence
The photographs submitted by Liwanag, taken during her encounters with Judge Lustre, were scrutinized. While these did not overtly depict inappropriate conduct, they raised questions regarding the nature of their relationship. Respondent's counter-claims regarding extortion intentions were deemed unconvincing, as Liwanag's detailed accounts were indicative of her distress and sense of exploitation
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Background of the Case
- Complainant Lualhati M. Liwanag lodged a formal complaint against Judge Paterno H. Lustre, presiding judge of the Municipal Trial Court in Calamba, Laguna, on September 19, 1995.
- The complaint alleged "gross immorality and grave misconduct" by Judge Lustre, specifically sexual molestation.
- Accompanying the complaint was a sworn statement detailing the alleged incidents of sexual misconduct by the judge.
Details of the Allegations
- Liwanag's husband, Jose B. Zafra, had filed multiple cases against Oscar Chua and others for violations of B.P. 22 (Bouncing Checks Law), amounting to approximately 3.5 million pesos.
- Liwanag visited Judge Lustre’s chambers several times to inquire about the status of these cases and to request scheduled hearings.
- During these visits, Liwanag alleged that Judge Lustre made inappropriate advances, including physical touching and sexual propositions.
- Specific incidents were described, including:
- An encounter in his chamber where the judge touched her inappropriately.
- A car ride where the judge kissed her and caressed her breast.
- A coerced sexual act in his office where the judge exposed himself and demanded oral sex.
- Liwanag claimed these encounters were motivated by the judge’s control over the hearings, which were being deliberately delayed.
Complainant's Evidence
- Liwanag provided supporting evidence, including:
- A series of photographs showing her and Judge Lustre together at various locations, including the Riverview Resort.
- A receipt from the Riverview Resort dated J