G.R. No. MTJ-97-1120 February 21, 2000
National Bureau of Investigation vs. Judge Ramon B. Reyes

FACTS

The National Bureau of Investigation (NBI) filed an administrative complaint for malfeasance against respondent Judge Ramon B. Reyes of the Municipal Circuit Trial Court (MCTC) of Mabini-Tingloy, Batangas. The case stemmed from an incident where four individuals were arrested and charged for violating the Dangerous Drugs Act. The mothers of three accused approached Judge Reyes to plead for their sons’ release. Respondent judge allegedly promised to dismiss the case in exchange for P240,000, later reduced to P15,000. The mothers reported this to the NBI, which orchestrated an entrapment operation using marked and dusted money.
During the entrapment on December 5, 1996, the mothers and an NBI agent delivered the marked money to Judge Reyes’s chambers. Following a pre-arranged signal, NBI operatives entered but initially could not locate the money. Respondent later confessed to taking the envelope containing the marked money using a handkerchief and placing it inside his desk drawer, from where it was recovered. An information for violation of the Anti-Graft and Corrupt Practices Act was subsequently filed against him before the Sandiganbayan.

ISSUE

Whether respondent Judge Ramon B. Reyes is administratively liable for gross misconduct and conduct unbecoming of a judicial officer and a member of the Bar.

RULING

Yes, respondent Judge Ramon B. Reyes is administratively liable. The Supreme Court adopted the findings of the Investigating Justice, which held that the evidence conclusively established respondent’s guilt. The defense that his constitutional rights during custodial investigation were violated was deemed irrelevant in the administrative proceeding, which is separate from the criminal case and requires only substantial evidence. The Court found the testimonial and physical evidence, including the recovery of the marked money from his possession, to be credible and sufficient.
The act of demanding and receiving money in exchange for a favorable judicial action constitutes gross misconduct and a severe violation of the Code of Judicial Conduct. It undermines public confidence in the integrity of the judiciary. The Court emphasized that a judge’s conduct must be beyond reproach. Respondent’s actions demonstrated moral unfitness and warranted the ultimate administrative penalty. Consequently, the Court dismissed him from service with forfeiture of all benefits and disbarred him from the practice of law for conduct unbecoming of a member of the Bar.