A.M. No. RTJ-17-2506 - Office of the Court Administrator vs. Reyes

Case Summary (A.M. No. RTJ-17-2506)

Relevant Legal Framework and Investigative Actions

The administrative case was initiated following President Duterte’s public naming of judges allegedly connected to illegal drugs. Retired Justice Roberto A. Abad was appointed by the Supreme Court as the sole investigator. After investigation, Judges Exequil L. Dagala, Adriano S. Savillo, and Domingo L. Casiple, Jr. were cleared for lack of evidence. However, Justice Abad’s February 2017 report recommended filing administrative charges against Judge Reyes. The Supreme Court directed the OCA to investigate further, including a review of Judge Reyes’s case dispositions and inquiries with related personnel and witnesses.

Summary of Evidence and Allegations

The OCA uncovered affidavits and testimony revealing serious allegations that Judge Reyes engaged in corrupt practices involving the exchange of monetary bribes for the acquittal of accused persons, particularly drug offenders. Affidavits from witnesses, including Paul Black, Melchora Nagen, Charito Oliva, Edmar Buscagan, and attorney Lourdes Maita Cascolan Andres, detailed payment schemes ranging from PHP 50,000 to PHP 300,000. The modus operandi reportedly involved preparing alternative decisions for acquittal or conviction, with the acquittal rendered only upon timely payment through intermediaries, termed “bag women” or “fixers,” including Judge Reyes’s driver.

Irregular Judicial Practices and Procedural Violations

The OCA's judicial audit confirmed numerous questionable decisions, including abrupt motu proprio dismissals of drug cases before the prosecution rested its case, violations of procedural rules under Section 23, Rule 119 of the Rules of Court, and unauthorized entertainments of second motions for reconsideration prohibited by Section 2, Rule 52 of the Rules of Court. Specific cases reflected these irregularities where Judge Reyes dismissed cases prematurely or reversed convictions inconsistently, supporting suspicions that his decisions were influenced by extrajudicial considerations or corrupt motives.

Respondent Judge’s Defense

Judge Reyes denied the charges, asserting that his rulings were consistent with his independent judicial discretion and relevant jurisprudence, citing the Supreme Court’s 2017 ruling in Estipona Jr. v. Lobrigo, which declared unconstitutional the prohibition of plea bargaining under Republic Act No. 9165. He maintained that motu proprio dismissals were based on the insufficiency of evidence after the prosecution rested and that the second motion for reconsideration was granted due to the greater interest of justice, highlighting alleged procedural or factual defects in the cases.

Legal Standards Applied

The Supreme Court applied the 1987 Philippine Constitution as the basis for decision, emphasizing that judges are presumed well-versed in the law, especially assigned drug cases. Administrative liability requires proof of gross ignorance of the law, gross misconduct, or corruption with facts supported by substantial evidence. Gross ignorance denotes willful disregard of settled jurisprudence and procedural rules. Misconduct necessitates deliberate violation or gross negligence connected with official duties. For judicial officers, adherence to the New Code of Judicial Conduct, particularly Canons 1, 2, and 3, imposing standards of independence, integrity, impartiality, and maintaining public confidence, is mandatory.

Court’s Findings on Substantial Evidence of Liability

The Court found substantial evidence that Judge Reyes disregarded explicit statutory prohibitions on plea bargaining before the Estipona ruling and repeatedly violated procedural rules on evidentiary requirements and case dismissal. The premature dismissals without allowing the prosecution to complete the formal offer of evidence demonstrated gross ignorance of the law. The unauthorized acceptance of a second motion for reconsideration contravened clear procedural mandates. The Court also accepted as substantial evidence the testimonies and affidavits, notwithstanding hearsay aspects, recognizing their corroboration through judicial audit and investigation.

Findings on Gross Misconduct and Violation of Judicial Canons

The evidence showed clear circumstances of corruption, with Judge Reyes allegedly profiting from granting favorable decisions in exchange for bribes. This conduct struck at the core of judicial integrity, violating Canons 1 (i

Case Syllabus (A.M. No. RTJ-17-2506)

Background and Factual Antecedents

On August 7, 2016, President Rodrigo Roa Duterte publicly named seven judges allegedly involved in illegal drugs, four of whom were sitting judges including Judge Antonio C. Reyes, respondent in this case.
The Supreme Court designated Retired Justice Roberto A. Abad as sole investigator for a fact-finding investigation on the four named judges.
Reports cleared three judges of any involvement; however, Justice Abad recommended the filing of administrative charges against Judge Reyes in his report dated February 16, 2017.
The Supreme Court, upon accepting the report, directed further investigations including an inventory of cases decided by the respondent, and locating witnesses.
The Office of the Court Administrator (OCA) formally charged Judge Reyes for gross ignorance of the law, gross misconduct, and flagrant violations of the Canons of the New Code of Judicial Conduct.
Affidavits were obtained from various persons, including Paul Black, Melchora Nagen, Charito Oliva, Edmar Buscagan, and Atty. Lourdes Maita Cascolan Andres, revealing allegations of bribery involving sums ranging from ₱50,000 to ₱300,000 in exchange for acquittals in drug cases.
Allegations also included the use of intermediaries (“bag woman” and “bag men”) by the respondent judge to receive money for case outcomes.
The judicial audit confirmed numerous questionable acquittals, dismissals, and motu proprio orders issued by the respondent judge, often circumventing proper procedural requirements.
The respondent judge denied all allegations, attributing his rulings to the independent assessment of evidence and existing jurisprudence including the unconstitutionality of certain provisions prohibiting plea bargaining.
The OCA recommended forfeiture of benefits (except accrued leave) and perpetual disqualification from future public employment due to the gravity of the offenses and the respondent’s compulsory retirement.

Issues Presented

Whether Judge Antonio C. Reyes is administratively liable for gross ignorance of the law, gross misconduct, and for violations of Canons 1, 2, and 3 of the New Code of Judicial Conduct.

Judicial Standards and Principles Applied

In disciplinary proceedings against judges, the required quantum of proof is substantial evidence—evidence a reasonable mind might accept as adequate to support a conclusion.
Gross ignorance of the law entails disregard of basic rules and settled jurisprudence and requires a showing of bad faith, dishonesty, or corruption.
Judges are expected to be well-versed in laws governing their jurisdiction, especially in specialized areas such as illegal drugs cases under R.A. 9165.
Section 23 of R.A. 9165 prohibits plea bargaining for offences under the Act; violation of this is inexcusable until declared unconstitutional by the Supreme Court.
Motu proprio dismissals of cases must comply with procedural requirements, including allowing the prosecution the opportunity to be heard and the filing of a formal offer of evidence before dismissals are valid.
Section 2, Rule 52 of the Rules of Court prohibits second motions for rec