A.M. No. RTJ-01-1630. April 9, 2003. HEINZ R. HECK, complainant, vs. JUDGE ANTHONY E. SANTOS, respondent.
FACTS

Complainant Heinz R. Heck was a defendant in a civil case before respondent Judge Anthony E. Santos. After the defendants’ counsel was allowed to withdraw, the court issued an order resetting the hearing. The defendants did not receive this order. At the subsequent hearing, only the plaintiffs’ counsel appeared. Respondent judge then issued an order admitting all plaintiffs’ exhibits, deeming the defendants to have waived their right to present evidence, and submitting the case for decision. Notably, the judge authorized the plaintiffs’ counsel, Atty. Manuel Singson, to draft the decision. The defendants also did not receive a copy of this order. Atty. Singson submitted a draft decision, which respondent judge adopted verbatim in his October 2, 1996 decision.
An administrative complaint was filed against Judge Santos. The charges included violation of Rule 36, Section 1 of the Rules of Court for not personally preparing the decision; violation of the Code of Judicial Ethics for allegedly mingling with a party’s counsel; and gross ignorance of the law for the substantive rulings in the decision. Respondent judge defended his actions, arguing the defendants were negligent, his order for the counsel to draft was meant to expedite the case, and he adopted the draft only after careful study.

ISSUE

Whether respondent Judge Anthony E. Santos is administratively liable for his actions in relation to the drafting and rendition of the decision in Civil Case No. 94-334.

RULING

Yes, respondent judge is administratively liable. The Supreme Court found him guilty of violating Canons 2 and 3 of the Code of Judicial Conduct in relation to Section 1, Rule 36 of the Rules of Court. The core of the offense was his delegation of the decision-drafting to the winning party’s counsel and his verbatim adoption of that draft.
The legal logic is clear: a judge’s judgment must be the product of his own impartial deliberation and must be seen as such to preserve public confidence in the judiciary. Rule 36, Section 1 mandates that a judgment be “in writing, personally and directly prepared by the judge.” By ordering the plaintiffs’ counsel to draft the decision and copying it verbatim, respondent abdicated this non-delegable duty. This act constituted blatant judicial laziness and created an undeniable appearance of impropriety and partiality, regardless of the lack of proven malice or the correctness of the draft’s contents. The Court emphasized that a judge must not only be impartial but must also avoid any suspicion of unfairness.
As the violation was classified as a serious charge under Rule 140 of the Rules of Court, the prescribed sanctions included dismissal, suspension, or a fine of P20,000 to P40,000. Since respondent had already retired, a fine was imposed. The Court ordered a fine of P20,000.00, to be deducted from his retirement benefits. The prayer for disbarment was referred to the Integrated Bar of the Philippines for separate action.