A.M. No. RTJ-02-1669. April 14, 2004.
HON. JULIETA A. DECENA, et al., complainants, vs. JUDGE NILO A. MALANYAON, respondent.

FACTS

The complainants, municipal officials of Bula, Camarines Sur, filed a Joint Affidavit-Complaint seeking the dismissal and disbarment of respondent Judge Nilo A. Malanyaon. The complaint stemmed from his conduct during the regular session of the Sangguniang Bayan on February 21, 2000. The session’s agenda included the revocation of resolutions authorizing Rolando N. Canet, the judge’s nephew-in-law, to operate a cockpit. Judge Malanyaon attended as an observer but, during deliberations, repeatedly interrupted the proceedings.
He shouted accusations in the vernacular, calling the proceedings “lies” and telling the officials they were being deceived. He directed personal, insulting remarks at the presiding Vice-Mayor and a councilor, questioning their integrity, intelligence, and etiquette. His outbursts, delivered with a red face and blazing eyes, caused confusion and disrupted the session. The judge claimed his comments were a legitimate exercise of free speech and citizen’s arrest, made to expose corruption.

ISSUE

Whether respondent Judge Malanyaon is administratively liable for his conduct during the municipal council session.

RULING

Yes, the Supreme Court found Judge Malanyaon guilty of conduct unbecoming a judge. The legal logic rests on the elevated standards of conduct required of members of the judiciary, which extend beyond official duties to private behavior. The Code of Judicial Conduct mandates that a judge’s conduct must be free from impropriety and appear to be so. By attending a session concerning a relative’s business interest, the judge already risked creating an impression of using his office to influence the outcome, violating the rule against lending judicial prestige to advance private interests.
More critically, his intemperate and insulting language during a official public proceeding constituted gross misconduct. Judicial office demands dignity, restraint, and respect for other government bodies. His disruptive outbursts, far from being protected speech, showed a lack of the decorum essential to maintaining public confidence in the judiciary. The act of disturbing a municipal council session is, in fact, a criminal offense, underscoring the seriousness of his misbehavior. The Court imposed a fine of Twenty Thousand Pesos, considering his otherwise clean record, with a stern warning for any repetition. The penalty emphasizes that a judge must at all times act in a manner promoting public respect for the judicial institution.