Case Summary (A.M. RTJ-20-2600)
Antecedents
Roberto L. Obiedo filed a case for Estafa against the Spouses Nino Rico and Mary Anne Nery, which was assigned to Judge Santos. After the trial, the judge acquitted the accused but ordered them to pay Obiedo significant civil damages. Following this judgment, the judge sent a text message to the parties' counsels, communicating his concerns about his decision, proposing a possible motion for reconsideration or appeal, and appearing to express biases against local residents.
Complaint and Allegations
Obiedo filed a verified complaint against Judge Santos, asserting that the judge's text message constituted a gross violation of judicial conduct by undermining the finality of his own decision. He alleged that the judge's language suggested uncertainty regarding the correctness of his judgment and implied a bias that favored or disfavored parties based on local affiliations. These actions, according to Obiedo, violated the Code of Judicial Conduct, specifically relating to the judge's duty to maintain integrity and impartiality.
Respondent's Defense
Judge Santos defended his text message as a practical approach aimed at resolving the parties' disputes amicably rather than through litigation. He argued that his communication was intended to clarify his judgment and was not influenced by uncertainty regarding its correctness. Furthermore, he contended that his prior relationship with the counsels allowed for candid communication and was not indicative of impropriety.
Findings of the Office of the Court Administrator (OCA)
The OCA found Judge Santos liable for impropriety, asserting that his text message undermined the integrity of his judgment and established doubts about his impartiality. The prior administrative penalties and infractions against Santos, which included issues of misconduct and inefficiency, were also highlighted by the OCA when formulating their recommendations.
Court's Ruling
The Court agreed with the OCA that Judge Santos was guilty of impropriety for sending the text message. It emphasized that judges must maintain an appearance of propriety in all activities, and sending such messages after a decision was rendered was inappropriate as it could lead to perceived biases.
Penalty Imposed
Despite the OCA's recommendation of a Php20,000 fine, the Court deemed this too lenient, considering Judge Santos&#
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Background
- The case revolves around a Verified Complaint filed by Roberto L. Obiedo against Hon. Soliman M. Santos, Jr., the Presiding Judge of Branch 61, Regional Trial Court in Naga City, Camarines Sur.
- The complaint alleges gross ignorance of the law and a violation of the Code of Judicial Conduct, seeking the dismissal of the respondent Judge from service.
Antecedents
- Obiedo initially filed a case for Estafa against the Spouses Nino Rico and Mary Anne Nery, which was assigned to respondent Judge.
- A judgment was rendered on December 17, 2018, acquitting the Nery spouses of criminal charges but ordering them to pay civil damages to Obiedo amounting to P1,390,000.00, plus interest.
Controversial Text Message
- Following the judgment, the respondent Judge sent a text message to the parties' counsels that conveyed his thoughts on the case outcome and hinted at the possibility of appealing the decision.
- The message included remarks suggesting that the Judge was contemplating a conviction, despite the acquittal, and expressed a desire for practical resolutions rather than strictly legal ones.
Allegations Against Respondent Judge
- Obiedo claimed that the text message sent by the respondent Judge constituted a gross violation of judicial conduct, portraying his ruling as needing justification.
- The complainant suggested that the Judge's actions indicated bias and uncertainty regarding his own decision, potentially