Obiedo v. Santos
REITERATIONFacts
The Antecedents: Complainant Roberto L. Obiedo (Obiedo) filed a case for Estafa against the Spouses Nino Rico and Mary Anne Nery (Nery Spouses), docketed as Criminal Case No. 2012-0426, which was raffled to respondent Judge Soliman M. Santos, Jr.'s sala. After trial, the respondent Judge acquitted the Nery Spouses but found them civilly liable to Obiedo for P1,290,000.00 in actual damages and P100,000.00 in moral damages, totaling P1,390,000.00, subject to interest. Procedural History: Following the promulgation of the judgment, respondent Judge sent a text message to the counsels of both parties. Obiedo, through new counsel, filed a Verified Complaint before the Supreme Court, alleging that the respondent Judge committed gross violation of the Code of Judicial Conduct and gross ignorance of the law by sending the text message, which he claimed appeared to justify the ruling, suggested errors, or indicated uncertainty about the decision's correctness. Obiedo also argued that the statement about not rendering "hometown decisions" showed bias against Naga City residents. The Office of the Court Administrator (OCA) found the respondent Judge liable for impropriety, recommending a fine of P20,000.00 and a reminder to be circumspect. The OCA noted previous administrative penalties against the respondent Judge in two instances: Susan R. Elgar v. Judge Soliman M. Santos, Jr. (A.M. No. MTJ-16-1880) and Peter U. Borromeo v. Judge Soliman M. Santos, Jr. (A.M. No. MTJ-15-1850). The Petition: The complainant prayed for the dismissal of the respondent Judge from the service due to alleged violations of Rule 1.01, Rule 2.01, and Rule 2.04 of the Code of Judicial Conduct, compounded by his previous administrative infractions.
Issue(s)
Whether or not respondent Judge Soliman M. Santos, Jr. should be held administratively liable for violation of the Code of the Judicial Conduct. Whether the respondent Judge's act of sending a text message to the parties' counsels after promulgating his decision constitutes impropriety, and the proper penalty to be imposed.
Ruling
The Court adopts the recommendation of the OCA, with a modification as to the penalty. Respondent Judge Soliman M. Santos, Jr. is found GUILTY of Impropriety and is SUSPENDED from his duties as presiding judge for SIX (6) MONTHS, without salary and other benefits. He is also STERNLY WARNED that a repetition of the same or similar act shall be dealt with more severely by the Court.
Ratio Decidendi
On the issue of administrative liability for violation of the Code of Judicial Conduct: The Court found sufficient basis to hold the respondent Judge guilty of impropriety for sending a text message to the parties' respective counsels after promulgating his decision. The Court emphasized that it was unnecessary for the respondent Judge to elaborate on the rationale for his disposition, as the promulgated judgment should have spoken for itself. The respondent Judge's supposed intent to discourage the parties from appealing could not justify the text message, especially since the judgment itself had already included a discussion on this matter. The Court agreed with the OCA that the message effectively cast doubt over the respondent Judge's impartiality, integrity, and competence in rendering his judgment. It was reiterated that the termination of a case does not preclude public criticism for acts that may render the disposition of a case suspect, underscoring the principle that judges must remain under constant public scrutiny. The Court cited various cases, such as Pertierra v. Judge Lerma and In re Justice Ong, to illustrate instances where judges were found to have acted improperly by engaging with parties or counsels outside official proceedings, thereby eroding public confidence in the judiciary. The respondent Judge's conduct was deemed to fall short of the high standards set by Canon 2 (Integrity) and Canon 4 (Propriety and the appearance of propriety) of the New Code of Judicial Conduct, placing his office and the entire Judiciary into a position of notoriety. On the issue of impropriety and the proper penalty to be imposed: Given the gravity of the respondent Judge's transgression and considering that this was not his first administrative case, the Court disagreed with the OCA's recommended penalty of a P20,000.00 fine, deeming it too lenient. The Court noted that the respondent Judge had previously been penalized in two instances, Susan R. Elgar v. Judge Soliman M. Santos, Jr. and Peter U. Borromeo v. Judge Soliman M. Santos, Jr., for similar types of conduct, specifically engaging with parties and their counsels outside of official court proceedings to influence their actions or encourage settlement. The Court concluded that the respondent Judge has a propensity for disregarding rules of propriety in his pursuit of "more practical" resolutions, even if his intentions were good. The Court found that the penalty of suspension for six (6) months, without pay and other benefits, was sufficient under the circumstances, considering the mitigating circumstance of good faith, as provided under Section 48 of the Revised Rules on Administrative Cases in the Civil Service. This penalty was deemed more appropriate than a fine, given the respondent Judge's repeated infractions and the inadequacy of previous fines to deter such conduct. The Court expressed hope that the suspension would allow the respondent Judge to re-focus on his judicial functions within the acceptable bounds of judicial conduct.
Main Doctrine
A judge is guilty of impropriety for sending a text message to the parties' counsels after promulgating a decision, as such communication is unnecessary, casts doubt on impartiality, integrity, and competence, and violates the Code of Judicial Conduct, particularly Canon 4 concerning propriety and the appearance of propriety.