Title
Office of the Court Administrator vs. Yu
Case
A.M. No. MTJ-12-1813, 12-1-09-MeTC, MTJ-13-1836, MTJ-12-1815, OCA IPI No. 11-2398-MTJ, 11-2399-MTJ, 11-2378-MTJ, 12-2456-MTJ, A.M. No. MTJ-13-1821
Decision Date
Nov 22, 2016
Judge Yu refused night court duties, citing legal concerns, leading to charges of insubordination, misconduct, and ignorance of the law. The Supreme Court dismissed her, disbarred her, and disqualified her from public office.

Case Summary (A.M. No. MTJ-12-1813, 12-1-09-MeTC, MTJ-13-1836, MTJ-12-1815, OCA IPI No. 11-2398-MTJ, 11-2399-MTJ, 11-2378-MTJ, 12-2456-MTJ, A.M. No. MTJ-13-1821)

Key Dates and Controlling Constitutional/Regulatory Source

Principal administrative dates and documents appearing in the record: Administrative Order No. 19‑2011 (27 January 2011); Executive Judge memorandum (9 February 2011); Judge Yu’s letters (February–July 2011); OCA responses (May 2011); suspension (effective 1 February 2012); Supreme Court decision (November 22, 2016). Governing law and authorities applied by the Court: 1987 Constitution (Article VIII — Supreme Court administrative supervision over all courts); Administrative Order No. 19‑2011 and Administrative Circular No. 58‑2002; 1991 Revised Rules on Summary Procedure and Rules of Court provisions (e.g., Rule 30 §9; Rule 110 §5; Rule 116 §6); New Code of Judicial Conduct; The New Civil Code; 2002 Revised Manual for Clerks of Court; OCA memoranda/circulars (e.g., Memorandum Circular No. 5‑2003 / OCA Circular No. 111‑2005); CSC Memorandum Circular No. 06‑05; A.M. No. 02‑9‑02‑SC (automatic conversion considerations for disciplinary proceedings against judges who are lawyers).

Consolidation and Nature of Proceedings

The Court consolidated multiple related administrative complaints and OCA investigative matters concerning Judge Yu’s alleged misconduct, insubordination, abuse of authority, oppression, gross ignorance of the law, and conduct unbecoming of a judge. The complaints originated from OCA, fellow judges, court personnel, and private individuals; several matters were administratively consolidated and processed together for resolution by the Supreme Court En Banc.

Core Factual Background — Night Courts and A.O. No. 19‑2011

A.O. No. 19‑2011 directed establishment of night courts in Pasay and Makati MeTCs to hear nighttime apprehensions and special cases under the Rule on Summary Procedure. Executive Judge Colasito issued a Pasay MeTC memorandum assigning night court schedules. Judge Yu annotated that she dissented, asserting legal questions and practical concerns (constitutional and procedural), and sent letters to the Court Administrator, the Pasay City Prosecutor, and the DOT articulating objections ranging from asserted exposure of police/prosecutors to arbitrary detention liability to employee welfare, workload, and security.

Core Factual Background — Personnel Appointments (Tejero‑Lopez and Lagman)

Judge Yu objected to and actively resisted the OCA‑SPBLC appointment of Leilani A. Tejero‑Lopez as Branch Clerk of Court III (Branch 47) despite the Board’s recommendation and the Chief Justice’s approval. The resistance included threats and communications urging withdrawal, alleged coercion, and refusal to administer the appointee’s oath; Ms. Tejero‑Lopez eventually was appointed and alleged pressure caused an initial withdrawal attempt. Judge Yu also protested the appointment of Mariejoy P. Lagman (demoted legal researcher appointed Clerk III, RTC Branch 108) despite a pending administrative complaint against Ms. Lagman.

Core Factual Background — Internal Court Management and Staff Complaints

Court staff of Branch 47 and four MeTC judges filed complaints alleging Judge Yu: repeatedly threatened and harassed personnel; made intimidating remarks; required unusual documentary submissions and approvals; directed audits and allegations against OCA officials; and displayed disrespect to colleagues and Court officials. Staff alleged oppression, abusive conduct, and operational irregularities in the handling of court documents and processes.

Core Factual Background — Procedural Acts in Court (OIC, OJTs, receipt of evidence)

Complaints alleged Judge Yu designated an Officer‑in‑Charge (Mr. Ferdinand Santos) who lacked required qualifications; permitted or delegated court tasks to on‑the‑job trainees (OJTs); and authorized ex parte reception of evidence or other procedural acts before non‑bar personnel. Complaints further alleged she allowed criminal proceedings or arraignments and plea changes without actual participation of the public prosecutor.

Core Factual Background — Sick‑leave and Allegation of Oppression

Mrs. Josefina Labid complained that Judge Yu refused to sign or approve leave applications of her son Noel (utility worker diagnosed with advanced cancer), notwithstanding submission of medical certificates and clinical abstracts. The complaint asserted that Judge Yu’s refusal caused hardship, demonstrated vindictiveness for the son’s participation in complaints against her, and amounted to oppression and grave abuse in administrative supervision of staff leave.

Core Factual Background — Electronic Communications and Conduct Unbecoming

Judge Emily L. San Gaspar‑Gito alleged that Judge Yu sent repeated electronic messages (Yahoo and Facebook) containing sexual innuendoes and harassing content, created or used fake profiles, and otherwise stalked or vexed the complainant online. Judge Yu disputed authorship of some items, claimed messages were innocuous double entendres or originated from the complainant, but the MISO extracted and certified the messages from the complainant’s accounts; CA Justice Hakim S. Abdulwahid recommended a three‑month suspension for simple misconduct and conduct unbecoming.

OCA Evaluation and Recommendations

The OCA, after comprehensive evaluation, recommended that Judge Yu be found guilty of insubordination, gross ignorance of the law, refusal to perform official functions, gross misconduct violating the Code of Judicial Conduct, grave abuse of authority, oppression, and conduct unbecoming, and recommended dismissal from the service with forfeiture of all benefits (except accrued leave) and disqualification from future public appointments. The OCA specified which acts it considered proven (e.g., refusal to comply with A.O. No. 19‑2011, refusal to honor valid appointments, issuance of show‑cause orders against colleagues, improper handling of leave for Noel Labid, procedural irregularities) and noted certain allegations it did not sustain.

Court’s Legal Analysis — Administrative Supervision and Insubordination

Relying on the Court’s constitutional administrative supervision (Article VIII, Section 6, 1987 Constitution) and the administrative nature of A.O. No. 19‑2011, the Court concluded that a judge must obey valid administrative directives of the Supreme Court. Judge Yu’s public and persistent refusal to comply, her direct communications to the DOT and police, and her public dissent improperly undermined the Court’s authority and constituted gross insubordination and gross misconduct. The Court emphasized that judicial officers have reduced latitude to publicly oppose supervisory administrative directives once validly issued.

Court’s Legal Analysis — Refusal to Honor Appointments; Abuse of Authority and Oppression

The Court held the OCA‑SPBLC appointments of Tejero‑Lopez and Lagman were valid and that pendency of administrative complaints does not, by itself, disqualify an employee from promotion under applicable personnel rules. Judge Yu’s rejection of the appointments, her intemperate characterizations of the appointments as “void ab initio” and “a big joke,” and threats to file charges against appointees constituted gross insubordination, grave abuse of authority, and oppression (including coercion or intimidation toward a subordinate to withdraw). The Court applied prior administrative jurisprudence that a presiding judge’s endorsement is recommendatory and the OCA’s appointment authority is paramount.

Court’s Legal Analysis — Improper Use of Court Processes and Disqualification Duties

Judge Yu issued a show‑cause order directed at fellow judges and court personnel in relation to allegedly copied trial‑record items used in administrative complaints; the Court found this to be an abuse of the judicial process, an act of retaliation, and a failure to disqualify herself where impartiality and the appearance of impartiality required recusal under the New Code of Judicial Conduct (Canon 3 §5 and Canon 4 §8). The Court stressed that a respondent judge is not the appropriate adjudicative authority for allegations that serve as evidence in administrative complaints against her.

Court’s Legal Analysis — Procedural Violations (OJTs, OIC designation, ex parte evidence, prosecutor presence)

The Court sustained findings that: (a) Judge Yu’s November 2010 memorandum delegating encoding and court tasks to a student (Ms. Rosali) contravened OCA Circular No. 111‑2005 (which implements Memo Circular No. 5‑2003 prohibiting OJT/practicum in court offices); (b) designating a first‑level personnel (Mr. Santos) as acting Branch Clerk (OIC) violated CSC Memorandum Circular No. 06‑05 (designees must be within their level); (c) Section 9, Rule 30 requires any delegation to receive ex parte evidence to be made to the clerk of court who is a member of the Bar — allowing reception of such evidence before a non‑bar OIC breached mandatory procedural rules; and (d) Section 5, Rule 110 and Section 6, Rule 116 of the Rules of Court require prosecution under the direction and control of the public prosecutor and safeguards for arraignment where counsel is absent; Judge Yu’s allowance of prosecutions or plea changes without the public prosecutor or without clear voluntary, knowing waivers by accuseds constituted gross ignorance of elementary procedural law.

Court’s Legal Analysis — Leave Denial and Oppression; Compliance with Clerks’ Manual

The Court applied the 2002 Revised Manual for Clerks of Court provisions on sick leave (paragraphs 2.2.1 and 2.2.2) and concluded Noel Labid’s submitted medical certificates and clinical abstracts sufficed to support sick‑leave approval; Judge Yu’s insistence on additional or different documentation and denial of the leave were unjustified and demonstrated vindictiveness tied to the employee’s participation in complaints. This conduct a

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