Case Summary (A.M. No. RTJ-08-2119)
Allegations of Demeaning Remarks
The transcript showed Judge Belen repeatedly challenged Mane’s competence by referring to his alma mater (Manuel L. Quezon University), asserting “not all law students…are created equal,” and insisting that Mane could not equate himself to a University of the Philippines graduate. The judge’s remarks included sarcastic questioning, threats to hail Mane to the Integrated Bar of the Philippines (IBP) for failing to apologize, and personal boasts regarding his own integrity and assets.
Respondent’s Justifications and Contempt Motions
In his comments, Judge Belen contended that Mane’s earlier “Urgent Motion to Inhibit” and related pleadings impugned the judge’s integrity and competence. He explained that, in response to those imputed doubts, he issued two orders dated June 5, 2006 directing Mane to explain why he should not be cited for contempt due to alleged “editing” of the transcript and malpractice in the inhibition motion.
Withdrawal and OCA Evaluation
Mane withdrew his complaint on September 4, 2006, but the OCA proceeded with its investigation, noting that a complainant’s withdrawal does not divest the Court’s disciplinary authority. The sole issue was whether Judge Belen’s statements and conduct during the hearing violated the Code of Judicial Conduct.
OCA’s Findings on Temperance and Courtesy
The OCA found no dispute over what transpired, as evidenced by the stenographic notes. It emphasized that judges must be temperate and courteous; that insulting language questioning a lawyer’s capability based on school affiliation is “clearly unwarranted and inexcusable”; and that judges must avoid controversial tones and public humiliation of counsel. The OCA recommended reprimand under Canon 3.
Supreme Court Deliberation and Applicable Ethical Rule
The Supreme Court required parties to submit on existing pleadings. It relied on Rule 3.04 of the Code of Judicial Conduct, which mandates that a judge be “patient, attentive, and courteous to lawyers…litigants, witnesses, and others appearing before the court,” avoid intemperate language, unnecessary displays of learning, and controversies that obscure case merits.
Transcript Illustrations of Intemperate Conduct
Verbatim excerpts confirmed Judge Belen’s indulgence in sarcastic, boastful, and personal discourse. He challenged Mane to prove corrupt or ignorant, flaunted his asset declarations, referred to Mane as “still young,” invoked family ties, and criticized Mane’s professional respect for the court system. The judge also rebuked the lawyer for charging “into the windmill” and lectured him on patrimony and procedure in a dem
...continue readingCase Syllabus (A.M. No. RTJ-08-2119)
Facts of the Case
- On February 27, 2006, during the hearing of Civil Case No. 3514-2003-C ("Rural Bank of Cabuyao, Inc. v. Samuel Malabanan, et al."), Presiding Judge Medel Arnaldo B. Belen made remarks directed at Atty. Melvin D.C. Mane regarding his law school background and professional competence.
- Stenographer Elenita C. de Guzman recorded the proceedings by tape and transcribed them into stenographic notes.
- Atty. Mane filed a letter-complaint dated May 19, 2006 (received May 26, 2006) charging Judge Belen with humiliating and berating him on the record.
- Atty. Mane had earlier filed, on April 24, 2006, a motion to compel production of the unedited tape recording; this motion remained unacted upon when he filed the administrative complaint.
- The respondent judge never denied the occurrence of the insulting statements but justified them as a response to what he perceived as an assault on his integrity and judicial competence.
Procedural History
- May 26, 2006: Administrative complaint filed with the Office of the Court Administrator (OCA).
- June 14, 2006: Judge Belen filed Comments, asserting that Atty. Mane’s December 15, 2005 motion to inhibit contained imputation of dishonesty against him, justifying his reaction.
- June 5, 2006: By separate orders, Judge Belen directed Atty. Mane to explain why he should not be cited for contempt.
- September 4, 2006: Atty. Mane withdrew his complaint, describing it as impulsive.
- November 7, 2007: OCA Report concluded that withdrawal did not bar the disciplinary proceeding and recommended reprimand for violation of Canon 3 of the Code of Judicial Conduct.
- January 21, 2008: The Supreme Court required the parties to manif