G.R. No. RTJ-00-1564. July 26, 2001.
Marissa M. Gordon and Jose B. Navarro, complainants, vs. Judge Frisco T. Lilagan, Regional Trial Court, Branch 34, Tacloban City, respondent.

FACTS

Two administrative complaints were filed against Judge Frisco T. Lilagan. Jose B. Navarro alleged the judge falsified his certificate of service, that the judge’s wife presided over clerks’ meetings, engaged in selling goods at the courthouse, and that the judge used provincial funds for personal trips. Marissa M. Gordon, a Legal Researcher in the judge’s court, alleged that on December 16, 1999, the judge’s wife, without provocation, manhandled her inside the judge’s chambers, causing hematoma, as shown by a medical certificate. Gordon further alleged the judge’s wife, though not an employee, was always in the office, sold products, acted as the judge’s “alter ego” by running the court, presiding over staff meetings, assigning workloads, and discussing case merits, all with the judge’s allowance and tolerance. In his comment, the judge denied the allegations, claimed the Navarro complainant was fictitious, admitted his wife stayed in his office but argued it was not prohibited, and stated his wife assisted him with his caseload due to her prior judicial experience. The case was referred to an Investigating Justice, who framed the issues around whether the judge allowed his wife to interfere in judicial functions, access court records, conduct business on premises, and whether the manhandling incident occurred with the judge’s involvement.

ISSUE

1. Whether respondent judge is administratively liable for the acts complained of by Jose B. Navarro.
2. Whether respondent judge is administratively liable for allowing his wife to interfere in his judicial functions, access court records, and conduct business within court premises.
3. Whether respondent judge is administratively liable for the alleged manhandling of complainant Gordon by his wife.

RULING

1. The complaint filed by Jose B. Navarro is DISMISSED. The charges were unsubstantiated, and the complainant’s identity was questionable.
2. Respondent judge is SEVERELY REPRIMANDED for allowing his wife to have access to the records of cases in his court. A judge must ensure the confidentiality of court records and prevent any unauthorized access, as emphasized in Supreme Court Circulars and jurisprudence.
3. Respondent judge is DIRECTED to minimize his wife’s presence in his court to prevent the impression that she is interfering with or influencing him in the discharge of his judicial functions. The Court found the charge of the wife conducting business on premises was not sufficiently proven. Regarding the manhandling incident, the evidence was conflicting and did not establish the judge’s personal involvement or blame for the altercation; thus, no administrative liability was attached to him for that specific incident.