G.R. No. A.M. No. 01-12-01-SC & A.M. No. SB-02-10-J; January 16, 2003
IN THE MATTER OF THE ALLEGED IMPROPER CONDUCT OF SANDIGANBAYAN ASSOCIATE JUSTICE ANACLETO D. BADOY, JR.; JOSEPH E. ESTRADA, ET AL. vs. ASSOCIATE JUSTICES ANACLETO D. BADOY, JR., AND TERESITA LEONARDO-DE CASTRO

FACTS

In A.M. No. 01-12-01-SC, Justice Anacleto D. Badoy, Jr. was the subject of an administrative complaint for conduct unbecoming a magistrate. On November 29, 2001, he traveled via ambulance to a television station for a live interview to publicly announce the loss of a Resolution he had penned in the plunder case against former President Joseph Estrada. He claimed he used the ambulance because he felt ill and intended to proceed to a hospital afterward. The act drew significant media criticism and ridicule, prompting the Supreme Court to require an explanation.
In the consolidated case, A.M. No. SB-02-10-J, complainants, including former President Estrada and his counsel, charged Justices Badoy and Teresita Leonardo-De Castro with various offenses arising from the pre-trial and trial of the plunder case. Specific allegations included dishonesty in drafting a pre-trial order, oppression for ordering a sheriff to escort lead counsel Atty. Rene Saguisag out of the courtroom during a heated argument, violating rules by setting frequent trial dates without consultation, and improperly appointing counsel de officio for the accused when their lawyers were absent.

ISSUE

The primary issue is whether the respondents, Justices Badoy and De Castro, committed acts constituting violations of the Code of Judicial Conduct warranting administrative sanction.

RULING

The Court found Justice Badoy administratively liable for impropriety in A.M. No. 01-12-01-SC. His decision to use an ambulance to go to a television station for a personal announcement, regardless of his claimed illness, was a clear misuse of a privilege that conveyed a sense of urgency and importance not aligned with a judicial duty. This act, which became a public spectacle, violated the standard that judges must avoid impropriety and the appearance of impropriety in all activities, as it eroded public confidence in the judiciary. For this, he was fined P20,000.
In A.M. No. SB-02-10-J, the charges against both justices were dismissed for lack of merit. The Court held that the incorporation of the exhibit admission in the pre-trial order was a procedural error, not an act of dishonesty. The order to remove Atty. Saguisag from the courtroom was a valid exercise of the court’s inherent power to control its proceedings and prevent disorder, as his simultaneous arguing despite warnings constituted misbehavior. The setting of trial dates was within the court’s discretion to ensure a speedy trial. The appointment of counsel de officio was a permissible measure to avoid a miscarriage of justice when the accused’s counsel were absent without valid justification, and it did not constitute a denial of the right to counsel.