G.R. No. RTJ-01-1631 August 14, 2003
OFFICE OF THE COURT ADMINISTRATOR, Petitioner, vs. JUDGE JAIME F. BAUTISTA, Regional Trial Court, Branch 75, Valenzuela, Metro Manila, Respondent.

FACTS

Respondent Judge Jaime F. Bautista was the presiding judge of a civil case for damages. After he issued a writ of preliminary attachment against the defendant bus company, its liaison officer, Ranel Paruli, alleged that the judge, through a sheriff, demanded a P10,000 bribe in exchange for issuing an order to lift the attachment. Paruli claimed he delivered P5,000 to Judge Bautista at his residence on March 16, 2001, after which the judge signed the lifting order. The balance was due on March 19. Instead of paying, the company filed a complaint with the NBI.
An entrapment operation was conducted on March 20, 2001. NBI agents apprehended Judge Bautista inside his chambers allegedly receiving the marked P5,000 balance. Forensic examination confirmed fluorescent powder on his hands. Based on news reports of his arrest for direct bribery, the Office of the Court Administrator filed an administrative complaint, and the Court indefinitely suspended the judge.

ISSUE

Whether respondent Judge Jaime F. Bautista is administratively liable for gross misconduct and conduct prejudicial to the best interest of the service.

RULING

Yes, respondent Judge is administratively liable and is dismissed from service. The Court found the evidence sufficient to establish his guilt by substantial evidence, the standard in administrative cases. The sworn statements of Paruli and a driver corroborated the bribery attempt and the initial payment at the judge’s house. Crucially, the entrapment operation provided direct physical evidence: the judge was caught receiving the marked money, and forensic tests confirmed powder traces on his hands.
The judge’s defense—denial and a claim of being framed—was unavailing. The Court found it improbable that the bus company would orchestrate an entrapment when the judge’s order to lift the attachment was already favorable to them. His attempt to attribute the scheme to staff members without his knowledge was unconvincing and unsupported. A judge’s conduct must be beyond reproach. By demanding and receiving money in connection with a case, respondent committed gross misconduct, a grave offense that erodes public trust in the judiciary. Such act is inherently prejudicial to the administration of justice. The penalty of dismissal, with forfeiture of benefits and disqualification from government re-employment, is warranted to preserve judicial integrity.