A.M. No. MTJ-00-1266. April 6, 2000
PROSECUTOR SALVADOR C. RUIZ, complainant, vs. JUDGE AGELIO L. BRINGAS, Municipal Trial Court in Cities, Branch 1, Butuan City, respondent.

FACTS

Prosecutor Salvador C. Ruiz filed an administrative complaint against Judge Agelio L. Bringas for serious misconduct and inefficiency, citing the judge’s use of intemperate and demeaning language. During a hearing on August 19, 1998, in a criminal case for falsification, an exchange occurred after the accused pleaded guilty. The prosecutor requested time to submit a formal penalty recommendation. Respondent Judge reacted by stating, “Put it on record that Prosecutor Ruiz does not know how to compute. Put it on record also that Fiscal Ruiz took the Bar three times.” The prosecutor retorted regarding the judge’s alma mater, leading to a further unseemly argument. In another case, the judge’s written order sarcastically commented about a prosecutor’s absence, suggesting the prosecutor might be “in hell or in purgatory.” Complainant also alleged the judge had a pattern of berating other lawyers.
The complaint further noted respondent had two prior administrative cases: one resulting in a fine for oppression and another in an admonition for intolerance. Additional charges included misrepresenting himself as an Ateneo Law School graduate and improperly changing his court’s designation to “City Trial Court” instead of the statutory “Municipal Trial Court in Cities.”

ISSUE

Whether respondent Judge Agelio L. Bringas is administratively liable for conduct unbecoming a judge based on the use of intemperate language and other alleged improprieties.

RULING

Yes, the Supreme Court found respondent Judge administratively liable. The Court emphasized that a judge must always be courteous and act in a manner promoting public confidence in the judiciary’s integrity. Canon 2 of the Code of Judicial Conduct requires a judge to avoid impropriety and its appearance. The judge’s remarks, made in open court and in orders, were demeaning, sarcastic, and utterly unbefitting his office. Such conduct erodes the dignity of the court and the respect owed to the legal process.
The Court rejected the judge’s defense that his comments were merely reactions to a prosecutor’s unpreparedness. Holding counsel to their duties does not justify petty, arbitrary, or overbearing behavior. The prior administrative sanctions for similar conduct demonstrated a pattern, making a mere admonition insufficient. The charge regarding misrepresentation about his law school was deemed trivial and inconsequential to his qualifications. However, the practice of using an incorrect court designation was properly admonished as it could cause public confusion.
Consequently, the Court adopted the Office of the Court Administrator’s recommendation. Respondent Judge Agelio L. Bringas was found guilty of conduct unbecoming a member of the judiciary. He was suspended from office for one month without pay and sternly warned that repetition would be dealt with more severely. He was also directed to cease using “City Trial Court” and to employ the proper statutory designation for his court.