AM MTJ 03 1492; (August, 2003) (Digest)

A.M. No. MTJ-03-1492, August 26, 2003
SPO4 Domingo B. Manaois vs. Judge Lavezares C. Leomo, MCTC, San Marcelino-Castillejos, Zambales

FACTS

Complainant SPO4 Domingo B. Manaois, a PNP officer, charged respondent Judge Lavezares C. Leomo with grave misconduct, obstruction of justice, and abuse of authority. The complaint stemmed from an incident on August 25, 1998, when Manaois attempted to arrest Rowena Corpuz based on a valid bench warrant. Corpuz, upon being informed of the arrest, rushed to a car where Judge Leomo was waiting. The judge then accompanied Corpuz back to Manaois’s office, confronted the officer, and after a brief exchange, grabbed Corpuz’s hand and left with her, thereby preventing the arrest. Judge Leomo later claimed he subsequently surrendered Corpuz to the PNP in Castillejos.
Following Manaois’s official report of the incident, the RTC in Las Piñas, where Corpuz’s case was pending, initiated contempt proceedings against Judge Leomo. In apparent retaliation, Judge Leomo issued an order charging Manaois with contempt for allegedly submitting a false report, set a hearing, and later issued a bench warrant for Manaois’s arrest when he failed to appear. This compelled Manaois to seek injunctive relief from the RTC of Olongapo City.

ISSUE

Whether respondent Judge Leomo is administratively liable for his actions in preventing the arrest of Rowena Corpuz and for subsequently initiating contempt proceedings against the arresting officer.

RULING

Yes, respondent Judge Leomo is administratively liable. The Supreme Court found the judge guilty of Gross Misconduct and violation of Canon 2 of the Code of Judicial Conduct. The legal logic is clear: a judge must not only be impartial but must also act in a manner that promotes public confidence in the judiciary’s integrity. By personally intervening to physically prevent a lawful arrest based on a valid warrant, Judge Leomo engaged in an act of obstruction of justice. His defense that he later surrendered the accused does not absolve him; his initial act of interference was a blatant disregard of his duty to uphold the law.
Furthermore, his subsequent acts of charging the complainant with contempt and issuing a bench warrant constituted a retaliatory abuse of judicial authority, intended to harass an officer for performing his lawful duty. This misuse of the court’s contempt power to settle a personal grievance or to retaliate against a valid report of judicial misconduct compounds the offense. The Court emphasized that judges must avoid even the appearance of impropriety. Judge Leomo’s actions, from the obstruction to the retaliatory charges, demonstrated a pattern of conduct utterly unbecoming of a judicial officer, warranting the ultimate penalty of dismissal from service with forfeiture of benefits and disqualification from reemployment in government.