Case Summary (AM-MTJ-10-1762)
Background of the Complaint
In December 2008, Judge Paderanga attempted to bring ten mango seedlings into Camiguin without a permit. Paga, acting in his capacity as a quarantine officer, inquired whether the judge possessed the necessary documentation for the seedlings. Judge Paderanga's dismissive response, coupled with a threat of physical violence, marked the start of tensions between the pair. The second incident occurred in April 2009, where Paga encountered Judge Paderanga and his sons, leading to a physical altercation instigated by the judge's sons, during which Judge Paderanga physically assaulted Paga.
Allegations Against Judge Paderanga
Paga subsequently filed an Affidavit-Complaint against Judge Paderanga, alleging a breach of Canon 2 of the Code of Judicial Conduct and charging the judge with gross ignorance of the law. Paga's assertions were that Judge Paderanga's actions during the altercations reflected not only inappropriate behavior for a judicial officer but also a lack of understanding of legal procedures surrounding quarantine regulations.
Response of Judge Paderanga
Judge Paderanga denied Paga's allegations, contending that he had no mango seedlings in his possession and asserting that he merely inquired about the necessity of permits given the absence of any pandemonium related to agricultural products. He further claimed that the altercation on April 19, 2009, was instigated by Paga's aggression and refusal to cooperate.
Investigating Judge's Report
The Investigating Judge, Judy A. Sia-Galvez, conducted an investigation and ultimately found Paga’s testimony credible. She reaffirmed that Paga was indeed slapped by Judge Paderanga and emphasized that even if the judges' sons had instigated the violence, Judge Paderanga bore responsibility for not preventing their misconduct. Sia-Galvez recommended an admonition for the judge for conduct unbecoming of a judge, while dismissing charges of gross misconduct or gross ignorance of law.
Office of the Court Administrator's Recommendation
Following the investigation, the Office of the Court Administrator (OCA) reviewed the case and aligned its findings with those of the Investigating Judge. However, it was noted that Judge Paderanga had a prior infraction, leading the OCA to recommend a fine of 20,000 pesos, citing his history as a factor substantiating the need for a stiffer penalty.
Court Ruling
The Court concurred with the OCA's findings, affirming that Judge Paderanga had violated several sections of Canon 4 of the Code of Judicial Conduct due to his unprofessional behavior. The Court expressed the importance of judges maintaining a high standard of propriety and how individual conduct can reflect on t
...continue readingCase Syllabus (AM-MTJ-10-1762)
Background of the Case
- The case arises from an Affidavit-Complaint filed by Mark Anthony I. Paga against Judge Emmanuel W. Paderanga, presiding judge of the Municipal Circuit Trial Court of Balingoan-Talisayan, Misamis Oriental.
- The complaint alleges violations of the Code of Judicial Conduct and gross ignorance of the law by Judge Paderanga.
Antecedents
- In December 2008, Judge Paderanga arrived at Benoni port, Camiguin Island, with ten mango seedlings. Quarantine personnel Paga approached him to inquire about a permit for the seedlings.
- Judge Paderanga questioned the need for a permit and, upon Paga's inability to provide legal backing, threatened him physically, stating, "then stand aside, otherwise, I will slap your face," before leaving with the seedlings.
- A second encounter on April 19, 2009, escalated into physical violence where Judge Paderanga and his sons allegedly attacked Paga, leading to injuries that required medical attention.
Initial Complaint and Response
- Paga filed a formal complaint against Judge Paderanga, accusing him of slapping him and allowing his sons to assault him, as well as questioning Paga's official duties as a quarantine officer.
- Judge Paderanga denied the allegations, asserting that he did not bring seedlings to Camiguin and that the confrontation was misrepresented. He claimed that Paga's actions during the second encounter provoked his sons.
Investigation Report
- The Office