A.M. No. RTJ-02-1699; October 15, 2003
VERNETTE UMALI-PACO, BERNARDINO D. NG, ORLANDO H. HABITAN and JOSEPHINE F. ANDRADA, complainants, vs. REINATO G. QUILALA, sued in his capacity as the Presiding Judge of the Regional Trial Court – Branch 57, Makati City, AIDA C. LOMUGDANG, officer-in-charge and LILIA N. BATU, Court Stenographer of the same Branch, respondents.

FACTS

Complainants, officers of the Philippine Retirement Authority (PRA), filed an administrative complaint against respondents for acts committed in Civil Case No. 01-112. They charged Judge Reinato G. Quilala with bias and partiality, citing instances where he allegedly coached a witness for the opposing party, granted motions without allowing PRA’s opposition, and threatened to issue an injunction ex parte. They further alleged that on February 19, 2001, Judge Quilala improperly delegated the reception of evidence and ruling on objections to Acting Clerk of Court Aida C. Lomugdang, who is not a member of the bar, in violation of Section 9, Rule 30 of the 1997 Rules of Civil Procedure. It was claimed that court stenographer Lilia N. Batu subsequently falsified the transcript to make it appear Judge Quilala presided over that session.
Judge Quilala defended his actions, asserting that his questions to witnesses were clarificatory and that expedited settings for injunctive relief were within his discretion. He denied improper delegation, claiming the parties consented to Lomugdang’s role for a hearing merely involving documentary reconciliation. He also stated he curtailed Atty. Umali-Paco’s arguments as she was not a party to the case.

ISSUE

Whether respondents are administratively liable for the alleged irregularities in the conduct of court proceedings.

RULING

The Supreme Court found respondents administratively liable. For Judge Quilala, the Court ruled that while a judge may ask clarificatory questions, his conduct—particularly the coaching of a witness and the improper delegation of judicial functions—transcended mere clarification and demonstrated bias. His delegation to a non-lawyer clerk of court to receive evidence and rule on objections violated the explicit requirements of Section 9, Rule 30, which mandates written agreement of the parties and that the delegate be a member of the bar. This, coupled with his discourteous interruption of counsel, constituted gross ignorance of procedure and conduct prejudicial to the administration of justice. The Court held that such actions eroded public confidence in judicial integrity.
Regarding the court personnel, the Court found Lomugdang liable for performing a function reserved by law to a member of the bar, even if directed by the judge. Batu was held liable for negligence in preparing a transcript that inaccurately reflected who presided over the hearing, failing in her duty to be a truthful recorder of proceedings. The Court emphasized that the conduct of all court personnel must be beyond reproach to preserve the judiciary’s honor.
Judge Quilala was fined P10,000. Lomugdang was severely reprimanded, and Batu was admonished. All were warned against future infractions.