A.M. No. MTJ-06-1659, A.M. No. P-06-2254, A.M. No. MTJ-09-1730; June 18, 2009
Anna Jane D. Lihaylihay vs. Judge Alejandro T. Canda; Judge Alejandro T. Canda vs. Anna Jane D. Lihaylihay

FACTS

These consolidated administrative cases stemmed from a conflict between Clerk III Anna Jane Lihaylihay and Judge Alejandro Canda. The dispute originated from Judge Canda’s opposition to the application of Jesus Alimpolo for a vacant Sheriff IV position, as he favored another candidate. Believing Lihaylihay was assisting Alimpolo, Judge Canda sent her text messages which she perceived as threats and had recorded in a police blotter. In response, Judge Canda sent a follow-up text message characterizing her act as a “declaration of war.”
Judge Canda then wrote formal letters to the Executive Judge accusing Lihaylihay of various infractions, including actively supporting Alimpolo and violating the Code of Conduct for Court Personnel. The letters contained highly offensive and derogatory language, describing Lihaylihay’s attire as akin to a “GRO” and her appearance as that of a “WHORE.” More critically, Judge Canda furnished a copy of one letter to a local newspaper, which published it with a headline translating to “Judge protests against sexy docket clerk.” Lihaylihay filed complaints for grave misconduct, while Judge Canda filed a counter-complaint against her.

ISSUE

Whether Judge Alejandro T. Canda is administratively liable for his actions against Clerk III Anna Jane D. Lihaylihay.

RULING

Yes, Judge Canda is guilty of Gross Misconduct. The Supreme Court emphasized that a judge’s behavior must be beyond reproach, as mandated by the Code of Judicial Conduct. Judge Canda’s actions—sending inflammatory text messages, writing letters with malicious and vulgar language, and, most egregiously, causing the publication of those defamatory allegations in a newspaper—constituted gross misconduct. The publication was not a protected judicial function but a deliberate act to humiliate a court employee publicly, which severely tarnished the integrity of the judiciary. This conduct displayed gross insensitivity, arrogance, and a failure to observe the high standards of decorum required of judicial office holders.
The Court dismissed the unsubstantiated charges against Lihaylihay for lack of evidence. Considering the gravity of the offense and that this was Judge Canda’s second administrative infraction, the Court imposed a fine of Forty Thousand Pesos (P40,000.00) with a stern warning that a repetition would be dealt with more severely. The ruling underscores that judges must exercise restraint and courtesy, especially towards court personnel, and must not use their position to wage personal vendettas that undermine public confidence in the justice system.