G.R. No. RTJ-11-2290 November 18, 2014
MARILOU T. RIVERA, Complainant, vs. JUDGE JAIME C. BLANCAFLOR, REGIONAL TRIAL COURT, BRANCH 26, STA. CRUZ, LAGUNA, Respondent.

FACTS

Complainant Marilou T. Rivera, who assisted litigants in obtaining judicial bonds, filed an administrative complaint against Judge Jaime C. Blancaflor for Bribery, Gross Misconduct, Immorality, and violation of the Anti-Graft and Corrupt Practices Act. The complaint stemmed from two incidents where Rivera sought the approval of bail bond reductions for accused individuals, Ricardo Catuday and Roel Namplata. For Catuday’s motion, which had the prosecutor’s “no objection,” court staff attempted to bring the motion to Judge Blancaflor at a restaurant he allegedly owned, but he refused to act on it, allegedly demanding payment and stating disapproval. The motion was later granted by another judge. For Namplata, Rivera secured Judge Blancaflor’s marginal note approving a reduced bail, but he later refused to honor the bond, increased the bail amount back, and allegedly conditioned release on the filing of a criminal case against Rivera. Rivera alleged Judge Blancaflor harbored ill will against her due to her involvement in a separate case (Special Proceeding No. 4605) where she was the attorney-in-fact for a party who filed a motion for inhibition against him. She also accused him of maintaining an illicit relationship with Noralyn Villamar. Judge Blancaflor denied all accusations, claiming Rivera was an unauthorized fixer, that he had a policy against reducing bail in drug cases, and that the allegations were fabricated due to a grudge from the prior case. He denied owning the restaurant or having an illicit affair.

ISSUE

Whether Judge Jaime C. Blancaflor is administratively liable for the charges of Gross Misconduct, Bribery, and Immorality.

RULING

Yes, Judge Jaime C. Blancaflor is found administratively liable for Gross Misconduct and Gross Ignorance of the Law. The Court adopted the findings of the Investigating Justice, which established that Judge Blancaflor exhibited bias and prejudice against Rivera by unjustifiably refusing to act on the bail reduction motions she facilitated, despite the prosecutor’s conformity, and by making disparaging remarks. His claim of a blanket policy against bail reduction in drug cases constituted gross ignorance of procedural law, as bail is a matter of right except for capital offenses. His conduct violated the Code of Judicial Conduct requiring impartiality and adherence to the law. The charge of bribery was not sufficiently proven. The charge of immorality, based on an alleged illicit relationship, was also not substantiated by clear evidence. However, due to the gravity of the proven offenses of Gross Misconduct and Gross Ignorance of the Law, which eroded public confidence in the judiciary, the Supreme Court imposed the penalty of DISMISSAL from service, with forfeiture of all retirement benefits except accrued leave credits, and with prejudice to re-employment in any government branch. He was also ordered disbarred.