AM 2258; (July, 1981) (Digest)
G.R. No. A.M. No. 2258-CFI July 20, 1981
VICENTE D. TRINIDAD, Ex-Mayor of Iguig, Cagayan, complainant, vs. JUDGE GABRIEL O. VALLE, JR., Court of First Instance of Ilocos Norte, Laoag City Branch II, respondent.
FACTS
Complainant Vicente D. Trinidad, former mayor of Iguig, Cagayan, charged respondent Judge Gabriel O. Valle, Jr. with engaging in partisan political activity. The charge stemmed from an incident where Judge Valle, while rendering rural service in Iguig, delivered a speech at a conference of barangay captains held at the house of Mayor Proceso Maramag. Affidavits from several individuals supported the allegation that the judge advised the barangay captains to support the leadership of Mayor Maramag and Minister of Defense Juan Ponce Enrile.
Judge Valle admitted delivering a speech in Ilocano at the gathering but denied favoring Maramag. He claimed he informed the audience that, as both the former mayor and the incumbent were acquaintances, he had no comment. He asserted he merely enjoined the barangay captains to follow the doctrine of the New Society and to vote honestly.
ISSUE
Whether Judge Gabriel O. Valle, Jr. violated the constitutional and statutory prohibitions against engaging in partisan political activity.
RULING
Yes, the Supreme Court found Judge Valle administratively liable. The Court held it was improper and indecorous for him to have taken part in the political meeting at Mayor Maramag’s house. His mere presence at such a gathering could reasonably be construed as an endorsement of Maramag against complainant Trinidad, rendering him vulnerable to charges of electioneering.
The legal logic is anchored on explicit constitutional and statutory mandates. The Constitution prohibits any officer or employee in the Civil Service from engaging, directly or indirectly, in any partisan political activity or taking part in any election except to vote. This prohibition is reiterated in the Civil Service Decree. The Court emphasized that a judge must exhibit a sense of delicadeza to avoid even the appearance of impropriety. Notwithstanding Judge Valle’s disclaimer, the circumstances—attending a political meeting in the home of an incumbent mayor during an apparent political context—constituted strong indications of partisan political activity. This conduct undermined public confidence in judicial impartiality. Consequently, the Court imposed a fine equivalent to his compensation for seven days.
