AM RTJ 15 2413; (September, 2018) (Digest)
G.R. No. A.M. No. RTJ-15-2413, A.M. No. RTJ-15-2414, A.M. No. RTJ-15-2415, A.M. No. RTJ-15-2416. September 25, 2018.
OFFICE OF THE COURT ADMINISTRATOR, Complainant, vs. JUDGE LYLIHA AQUINO, JUDGE RALPH LEE, JUDGE ROMMEL BAYBAY, and JUDGE MARINO RUBIA, Respondents.
FACTS
These consolidated administrative cases originated from news reports in 2013 concerning an alleged court fixer known as “Arlene” or “Ma’am Arlene,” who was depicted as wielding considerable influence over judges and justices, sponsoring lavish gifts and trips, and fixing high-profile cases. The reports were linked to allegations of intense and improper campaigning during the 2013 Philippine Judges Association (PJA) elections. The Supreme Court created an Ad Hoc Investigating Committee to probe the matter.
The Committee’s investigation focused on the election conduct of four Regional Trial Court judges who were candidates: Judges Lyliha Aquino, Ralph Lee, Rommel Baybay, and Marino Rubia. The Committee found that these judges likely violated the Court’s Guidelines on the Conduct of Elections of Judges’ Associations and the New Code of Judicial Conduct. Specifically, the judges were implicated for allegedly associating with and being supported by the purported fixer, “Ma’am Arlene,” in their election campaigns, thereby creating an appearance of impropriety and undermining public confidence in the judiciary.
ISSUE
Whether the respondent judges should be held administratively liable for their conduct in relation to the 2013 PJA elections and their alleged association with a reported court fixer.
RULING
Yes, the respondent judges are administratively liable. The Supreme Court, adopting the findings of the Ad Hoc Committee, found the judges guilty of violating the New Code of Judicial Conduct and the specific guidelines for judicial elections. The legal logic centers on the imperative for judges to avoid not only actual impropriety but also its appearance. Canon 4 of the Code mandates that a judge’s extra-judicial conduct must not undermine public confidence in the judiciary.
By actively campaigning and allegedly accepting support from an individual publicly identified as a “fixer,” the judges lent the prestige of their office to advance private interests and created a perception that they were susceptible to undue influence. This conduct, regardless of whether “Arlene” was conclusively proven to be a fixer, eroded the essential public trust in judicial independence and integrity. The Court emphasized that the judiciary’s strength depends on public confidence, and judges must be beyond reproach in all activities. The respondents’ actions, occurring in the context of an election for a judges’ association, were deemed inconsistent with the dignity of judicial office.
Consequently, the Court imposed the penalty of dismissal from service upon Judges Aquino, Lee, and Baybay, with forfeiture of all retirement benefits except accrued leave credits, and with prejudice to re-employment in any government branch. Judge Rubia was separately fined P40,000 for less grave misconduct, considering he had already compulsorily retired. The decision underscores that membership in the judiciary demands the highest standards of conduct to preserve its sanctity.
