AM 1895 CFI; (July, 1982) (Digest)
A.M. No. 1895-CFI. July 20, 1982. LAMBERTO MACIAS, complainant, vs. JUDGE GIBSON ARAULA, CFI, Branch II, San Juan, Southern Leyte, respondent.
FACTS
Complainant Lamberto Macias charged respondent Judge Gibson Araula with serious misconduct, oppression, and illegal participation in partisan politics. The charges stemmed from two sets of incidents. First, the judge was accused of delivering political campaign speeches for Kilusan ng Bagong Lipunan (KBL) candidates during rallies on March 20 and April 2, 1978, in Dauin, Negros Oriental, urging the public to vote for them and disparaging the opposition Pusyon Bisaya. Second, following the KBL’s electoral loss, the judge was alleged to have, on April 9, 1978, led family members and others in coercively ejecting Pusyon Bisaya vendors from the public market and confronting and challenging political opponents, with his son assaulting one individual.
The case was referred for investigation. The complainant presented witnesses who corroborated the allegations of electioneering speeches and the post-election market incident. In his defense, Judge Araula denied all charges. He testified that his appearances at the gatherings were merely to explain the non-partisan mechanics of the upcoming elections, such as block voting and regional representation. He also denied any involvement in the market altercation, asserting he had no authority to eject vendors.
ISSUE
Whether respondent Judge Gibson Araula is administratively liable for conduct unbecoming a judicial officer.
RULING
Yes, the respondent judge is administratively liable. The Supreme Court adopted the findings of the Investigating Justice. While it accepted the judge’s claim that his intent during the rallies was to educate the public on election procedures, the Court emphasized that a judge must avoid not only impropriety but also its appearance. By speaking at politically sponsored rallies during a heated campaign period, the judge placed himself in a situation where his actions could reasonably be perceived as partisan political activity, violating the Canons of Judicial Ethics requiring conduct beyond reproach.
Regarding the post-election incident, the Court found the judge’s conduct, even if provoked by political slurs against his wife, to be lacking the temperance, patience, and forbearance demanded of a magistrate. A judge must conduct himself in a manner above suspicion at all times. Consequently, the Court held the judge liable for the charges related to electioneering (I-A and I-B) and the confrontational conduct (II-B), as they demonstrated a failure to uphold the stringent standards of judicial decorum. Judge Gibson Araula was reprimanded and sternly admonished that a repetition would be dealt with more severely.