G.R. No. A.M. No. 1574-MJ. April 30, 1979.
Artemio Espayos, complainant, vs. Adelardo G. Lee, as Municipal Judge of Magallanes, Sorsogon, respondent.

FACTS

Complainant Artemio Espayos charged Municipal Judge Adelardo Lee with conduct unbecoming a judge and partiality. The charges stemmed from the judge’s handling of Criminal Case No. 2044 for less serious physical injuries, where the accused, Prodencio Pareja, assaulted Espayos. Espayos alleged that he informed the judge his injury was serious, demonstrating a nasal obstruction. His lawyer intended to amend the complaint to serious physical injuries.
Espayos further alleged that on January 27, 1977, without his knowledge, the accused was arraigned. Pareja, appearing without counsel, pleaded guilty to a lesser offense of slight physical injuries. The police commander did not object, and Judge Lee immediately sentenced Pareja to 15 days imprisonment. Espayos’s subsequent motion to prove damages was denied. Espayos also claimed Judge Lee later offered him P80, then P100, to settle, which he refused. A separate charge was that Judge Lee conducted court business primarily from his residence, not the municipal building.

ISSUE

Whether respondent Judge Adelardo Lee committed irregularities in office warranting administrative sanction.

RULING

Yes, the Supreme Court found respondent judge administratively liable and severely censured him. The legal logic is twofold. First, the judge erred in not allowing the offended party to prove the civil liability for damages after the criminal conviction. The judge incorrectly believed a separate civil action was always available. Under the Rules of Court, the civil action for civil liability is impliedly instituted with the criminal action unless expressly waived or reserved separately. By denying the motion to prove damages, the judge deprived the complainant of his right to seek civil indemnity within the criminal case, demonstrating a lack of awareness of fundamental procedure.
Second, the judge improperly held office in his residence. A judge is legally obligated to observe official hours at the court’s regular place of business to ensure public accessibility and maintain the judiciary’s integrity. Conducting official business from a private residence creates an appearance of impropriety and secrecy, undermining public confidence. The Court emphasized that a judge’s conduct must be free from any impropriety or its appearance. These acts constituted improper discharge of judicial duties. The Court issued a severe censure and warning that a more drastic penalty would follow for any similar future irregularities.