A.M. No. RTJ-08-2119. June 30, 2008. ATTY. MELVIN D.C. MANE, complainant, vs. JUDGE MEDEL ARNALDO B. BELEN, REGIONAL TRIAL COURT, BRANCH 36, CALAMBA CITY, respondent.
FACTS:

Atty. Melvin D.C. Mane filed an administrative complaint against Judge Medel Arnaldo B. Belen for conduct unbecoming of a judge. The complaint stemmed from a hearing on February 27, 2006, in Civil Case No. 3514-2003-C. During the proceedings, Judge Belen engaged in a demeaning discourse, specifically asking Atty. Mane if he graduated from the University of the Philippines College of Law. Upon learning that Atty. Mane was from Manuel L. Quezon University, the judge stated, “Then you cannot equate yourself to me because there is a saying… not all law students are created equal, not all law schools are created equal, not all lawyers are created equal.” The complainant attached the transcript of stenographic notes as evidence.
In his comment, Judge Belen justified his behavior by citing two motions filed by Atty. Mane which he perceived as direct assaults on his integrity and dignity. He claimed these motions maliciously implied that he issued an order for considerations other than the merits and that the court was engaged in editing transcripts. Consequently, he had issued orders for Atty. Mane to show cause why he should not be cited for contempt. Atty. Mane later withdrew his complaint, stating it was a result of impulsiveness.

ISSUE

Whether the statements and actions of Judge Belen during the February 27, 2006 hearing constitute conduct unbecoming of a judge in violation of the Code of Judicial Conduct.

RULING

Yes, Judge Belen is guilty of conduct unbecoming of a judge. The Court emphasized that a judge’s official conduct must be free from the appearance of impropriety and beyond reproach. Judges are required to be temperate, patient, and courteous in both conduct and language. The incident, as evidenced by the uncontested stenographic notes, revealed that Judge Belen used intemperate and insulting language that questioned the complainant’s capability based solely on his alma mater. This was an unwarranted argumentum ad hominem.
The Court held that a lawyer’s competence is presumed from passing the Bar Examinations, taking the lawyer’s oath, and signing the Roll of Attorneys, irrespective of the law school attended. While a judge may properly address perceived assaults on his dignity through contempt proceedings, he must not engage in supercilious personal discourse. Judge Belen’s conduct, including his public humiliation of counsel, fell below the standard of decorum. His actions constituted a light charge under Rule 140 of the Revised Rules of Court. Accordingly, Judge Medel Arnaldo B. Belen was REPRIMANDED and warned that a repetition would be dealt with more severely.