Case Summary (A.M. No. RTJ-20-2579 [Formerly A.M. No. 20-06-75 RTC)
Antecedents and Factual Findings
Assignment and Recovery of Court-Issued Laptop
• August 8, 2018: Supreme Court issued laptop (HP 240 G6, SN 5CD7525ZNo) to Judge Reyes, then-Acting Presiding Judge, Branch 39, RTC Roxas City.
• Upon transfer to Judge Caranzo, laptop returned December 27, 2019, to MISO for repair; January 3, 2020: backup of iPhone messages discovered.
• MISO downloaded iBackup Viewer, uncovered SMS/iMessage conversations implicating Judge Reyes in solicitations and receipt of bribes.
Forensic and Audit Investigations
• January 20, 2020: OCA engaged a private digital forensic expert to extract data; recovered messages, contacts, photos, videos, notes.
• OCA Investigating Team (Memorandum, March 12, 2020) confirmed Judge Reyes’s phone ownership and use of messages to demand bribes from lawyers and individuals in exchange for favorable case outcomes.
• Alleged corrupt transactions included “pabaon” for seminars, money and firearms for decisions favorable to litigants, dummy transactions in real-estate deals.
Audit Team Findings (December 10, 2020)
• Confirmed direct bribe solicitations in motions for bail, plea bargains, case dismissals, travel-abroad orders and acquittals.
• Reviewed 76 criminal cases: high dismissal rate, suspicious timing of decisions, irregular mediation conduct, delays, lack of evidentiary summaries.
• Noted failure to turn over subject firearms in nine decided cases under RA 10591; identified additional missing firearms and exhibits upon inventory by Judge Caranzo.
PNP CIDG Investigation (September 14, 2020)
• Routine follow-up on firearms cases led to interviews with litigants confirming Judge Reyes’s corrupt earnings and retention of firearms intended as evidence.
• PNP Report recommended filing criminal and administrative charges for corruption and irregularities.
Procedural Steps and Recommendations
Supreme Court En Banc Resolution (June 9, 2020)
• Re-docketed OCA Memorandum as A.M. No. RTJ-20-2579; considered a formal complaint; preventively suspended Judge Reyes.
• Ordered OCA to secure court premises, conduct judicial audit of Branches 39, 41, 43, and coordinate with Anti-Money Laundering Council.
Judicial Integrity Board Review (June 22, 2022)
• Summarized extensive message exchanges demonstrating bribery, case referrals, and retention of firearms.
• Recommended directing Judge Reyes to comment on OCA memoranda, PNP report, and audit findings.
• Proposed charges: gross misconduct (judicial ethics violations, bribery under RA 3019), serious dishonesty, gross immorality; recommended dismissal, forfeiture of benefits, disqualification.
Respondent’s Defense
• Claimed violation of constitutional right to privacy in obtaining private mobile data (exclusionary rule; “fruit of the poisonous tree” argument).
• Alleged messages were fake or tampered by Judge Caranzo, who possessed the laptop before MISO.
• Contended legal errors in case adjudications should be challenged by appeal, not administrative action.
• Asserted branch clerks of court were responsible for missing firearms and exhibits; COVID-19 lockdowns impeded return of materials.
Legal Analysis: Privacy and Admissibility of Evidence
Constitutional and Statutory Privacy Guarantees
• 1987 Constitution, Art. III, Sec. 2–3: inviolable right to be secure against unreasonable search and seizure; exclusionary rule requires suppression of unlawfully obtained evidence.
• Cybercrime Prevention Act and Rule on Cybercrime Warrants: regulates searches and seizures of electronic data, including mobile-phone contents, by warrant or under recognized exceptions.
Government-Issued Computers and Expectation of Privacy
• A.M. No. 05-3-08-SC (Computer Guidelines and Policies): Supreme Court-issued IT resources are owned and monitored by the Court; “no privacy in electronic communications” on court equipment.
• Pollo v. Constantino-David (2011): government-issued computer users have no reasonable expectation of privacy when employer policy authorizes monitoring.
• Morales case distinguished: personal computer vs. government-issued computer.
Application to Judge Reyes’s Case
• SMS/iMessage data were stored on the court-issued laptop, subject to MISO policy and monitoring; Judge Reyes had no reasonable expectation of privacy.
• No warrant requirement or exclusionary protection applied to government property searches under proper policies.
• Judicial audit evidence not “fruit of the poisonous tree” because PNP investigation and OCA audit would inevitably have discovered the same corrupt practices.
Determination of Administrative Liability
Standard of Proof
• Substantial evidence—reasonable ground a mind might accept as adequate to support misconduct findings.
Gross Misconduct (Serious Charge)
• Direct solicitation and receipt of bribes from litigants, lawyers, and local officials in exchange for favorable judicial actions.
• Violations of Canons 2 (Integrity), 3 (Impartiality), 4 (Propriety) of the New Code of Judicial Conduct; bribery under Anti-Graft and Corrupt Practices Act (RA 3019).
• Corruption undermines public confidence, tarnishes judicial integrity.
Simple Misconduct (Less Serious Charge)
• Failure to ensure safekee
Case Syllabus (A.M. No. RTJ-20-2579 [Formerly A.M. No. 20-06-75 RTC)
Facts and Antecedents
- On August 8, 2018, the Supreme Court assigned an HP 240 G6 laptop (SN 5CD7525ZNo) to Judge Reyes, then Acting Presiding Judge of RTC Branch 39.
- The laptop was transferred to Judge Josephine Caranzo upon her appointment to Branch 39; she returned it for repair or replacement on December 27, 2019.
- MISO examined the laptop on January 3, 2020: found an iPhone backup and, using iBackup Viewer, uncovered SMS/iMessage backups suggesting corrupt practices.
- The OCA hired digital forensic expert Dexter De Laggui on January 20, 2020 to verify MISO’s findings; recovered SMS/iMessages, contacts, photos, videos, and notes.
- Chief Justice Peralta issued Office Order No. 05-2020 directing the OCA to investigate and audit Branches 39, 41, and 43 of the RTC in Oriental Mindoro.
OCA Investigation and Initial Findings
- In a March 12, 2020 memorandum, the OCA investigating team concluded Judge Reyes was user of the laptop and owner of the iPhone 6s Plus.
- Messages showed Judge Reyes solicited money (“pabaon”) from lawyers and individuals for favorable case outcomes.
- Frequent correspondents included Atty. Eduardo M. Magsino, Atty. Marlo E. Masangkay, Atty. Lysander L. Fetizanan, and Mayor Joselito Malabanan.
- Specific corrupt acts found:
• Borrowing money for seminars;
• Using lawyers as “dummies” in real estate deals;
• Receiving cash, a car, and firearms in exchange for favorable orders. - Others named in messages: Sheriff IV Rodrigo Dimaandal (“Ringgo”); Process Server Roberto F. Fallaria; Mel Silva (judge’s representative); Atty. Crisalyn B. Lumanglas (drafted decisions).
OCA Recommendations and Supreme Court En Banc Resolutions
- OCA recommended:
• Treat the instant memorandum as a formal complaint;
• Preventively suspend Judge Reyes;
• Conduct judicial audits of RTC Branches 39, 41, 43;
• Coordinate with the Anti–Money Laundering Council for bank and money-transfer records. - On June 9, 2020, the Supreme Court:
• Docketed complaint as A.M. No. RTJ-20-2579;
• Preventively suspended Judge Reyes;
• Ordered securement of court premises and suspension of record movements;
• Directed OCA to audit branches and coordinate with the AMLC. - On June 16, 2020, Globe Telecom was ordered to identify owners of phone numbers recovered from the laptop.
Judicial Audit Teams and Case Reviews
- Three audit teams formed to examine 20 cases in Branches 39 and 43.
- In a December 10, 2020 report, audit teams found Judge Reyes:
• Demanded bribes for bail motions, plea bargains, acquittals, travel-abroad orders;
• Displayed favoritism and partiality in case dispositions. - Random review of 76 criminal cases showed unusually high dismissal rate and irregular decisions.
- Noted errors in:
• Maloles v. Aquino (annulment granted without hearing);
• Gara-Cruz v. Cruz (9-month delay in decision);
• Dy v. Dimapilis (judge proposed settlement figures in mediation);
• People v. Cabral (allowed travel