Title
Re: Laarni N. Dajao
Case
A.M. No. RTJ-16-2456
Decision Date
Mar 2, 2020
Judge Dajao fined for vulgar language and improper use of titles in court documents, violating judicial conduct standards.
vulgar conduct
unbecoming conduct
order
A

Case Summary (A.M. No. RTJ-16-2456)

Petitioner

An anonymous individual who filed a letter-complaint dated 15 January 2014 alleging vulgar and unbecoming conduct by Judge Dajao in an Order dated 27 November 2013 and objecting to the judge’s use of the honorifics “Dr.” and “Ph.D.”

Respondent

Judge Laarni N. Dajao, Presiding Judge of RTC Branch 27, Siocon, who authored the Order of 27 November 2013 that dismissed three criminal cases without prejudice and included intemperate expressions and appended academic titles to the judge’s name.

Key Dates

Order forming the basis of the complaint: 27 November 2013; anonymous complaint: 15 January 2014; respondent’s Comment: 6 May 2014; OCA Report and Recommendation: 26 January 2016; Supreme Court resolution adopting OCA recommendation and imposing discipline: March 2, 2020.

Applicable Law and Normative Framework

The resolution was decided under the standards set by the New Code of Judicial Conduct (A.M. No. 03-05-01-SC, effective 1 June 2004), specifically Canon 4, Sections 1 and 2 (propriety and the appearance of propriety), Canon 2, Rule 2.02 (prohibition against seeking publicity for personal vainglory), and related canons on judicial temperament and integrity. Procedural classification and penalty range derive from Section 10(1), Rule 140 of the Revised Rules of Court, which treats “vulgar and unbecoming conduct” as a light offense punishable by a fine between P1,000 and P10,000. Because the decision date is after 1990, the 1987 Constitution is the constitutional framework applied in assessing the public trust and institutional integrity implications of judicial conduct.

Facts Alleged in the Complaint

The anonymous letter asserted three principal complaints: (1) a pattern of unprofessional conduct in the judge’s language and demeanor observed during hearings; (2) the inclusion of the academic titles “Dr.” and “Ph.D.” after the judge’s name in court documents; and (3) the use of malicious, degrading, and obscene expressions in the 27 November 2013 Order in three criminal cases involving illegal possession of firearms and ammunition (Criminal Case Nos. 2013-08-05, -06, and -07), including quoted language allegedly referring to “big dick/penis,” “homophobic baklita,” “idiot,” “ugok,” “psychopath,” and insinuations of sexual relationships.

Respondent’s Position and Procedural History

In a Comment dated 6 May 2014, Judge Dajao characterized the complaint as malicious, noted that the underlying criminal cases were dismissed without prejudice (limiting his ability to respond substantively), and stated that he had accepted an apology from the PDEA Regional Director on behalf of the PDEA operatives mentioned in the Order. The OCA re-docketed the anonymous communication as a regular administrative matter, investigated, and in its 26 January 2016 Report found administrative liability, recommending that the judge be fined P5,000 with a stern warning.

OCA Findings and Recommendation

The OCA concluded that the challenged portions of the 27 November 2013 Order contained intemperate and insulting language unbefitting a member of the judiciary, and that the appended academic titles conveyed an appearance of egotism and unwarranted self-promotion. The OCA recommended re-docketing the matter and imposing a fine of P5,000 together with a stern warning that repetition would result in harsher sanctions.

Supreme Court Analysis — Propriety, Judicial Temperament, and Language

The Court adopted the OCA’s findings. It applied Canon 4, Sections 1 and 2 of the New Code of Judicial Conduct, which require judges to avoid impropriety and the appearance thereof and to conduct themselves with dignity, gravitas, temperance, patience and courtesy. The Court emphasized that the judge’s written language in the Order—characterizations such as “idiot,” “psychopath,” “big dick (penis),” “sadistic,” and “homophobic baklita,” as well as insinuations of sexual relations involving parties—fell short of the hallmark judicial temperament of sobriety and self-restraint, and thereby constituted vulgar and unbecoming conduct that erodes public confidence in the judiciary. The Court relied on precedent that intemperate language by a judge detracts from respect due to the office and is self-destructive, and reiterated that judges must avoid any impression of impropriety to protect judicial image and integrity.

Supreme Court Analysis — Use of Academic Titles and Prohibition Against Vainglory

The Court agreed with the OCA that appending “Dr.” and “Ph.D.” beside the judge’s name in the Order was unnecessary and conveyed an impression of vainglory or self-promotion. Citing Canon 2, Rule 2.02 and related precedent, the Court observed that judges must not seek publicity for personal vainglory, must refrain from using the courtro

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