## FACTS:

The case involves an administrative complaint against a judge named Ceferino Tigas, initiated by Ceferino Tigas himself, who was later found to be a fictitious character. Tigas wrote a letter to the Office of the Court Administrator of the Supreme Court, accusing the respondent judge of irregularities and corruption. The letter was referred to the National Bureau of Investigation (NBI) for investigation. The NBI agents conducted a discreet investigation and found that Tigas did not exist.

The NBI agents then contacted Candido Cruz, an accused in the respondent judge's court, who claimed in an affidavit that the judge had demanded P2,000 from him in exchange for a favorable action on his case. Based on this statement, the NBI agents set up an entrapment operation, during which Cruz handed over marked bills to the respondent judge. The judge denied receiving any money, but the marked bills were found in his possession. As a result, the judge was charged with bribery under Article 210 of the Revised Penal Code. The case was referred to Executive Judge Natividad G. Dizon for investigation and recommendation.

ISSUES

1. Whether the evidence presented in the administrative case against Judge Filomeno Pascual was sufficient to prove the charge of bribery beyond reasonable doubt.

2. Whether the rights to due process of Judge Filomeno Pascual were upheld in the administrative proceedings against him.

RULING

1. The Supreme Court found that the evidence presented was not sufficient to prove the charge of bribery against Judge Filomeno Pascual beyond reasonable doubt. The Court noted inconsistencies and irregularities in witness testimonies and the investigation process, particularly the manner of the alleged entrapment and the handling of the marked money.

2. The Court ruled that Judge Pascual's right to due process was violated in the administrative proceedings. The Court emphasized that Judge Pascual was not afforded an open trial where he could confront witnesses against him or present his own evidence in defense. This lack of due process led to the dismissal of the administrative case against him.

PRINCIPLES

1. Reasonable Doubt Standard in Administrative Cases: The need to establish charges such as misconduct, corruption, or bribery against a judicial officer beyond a reasonable doubt before imposing any disciplinary action.

2. Right to Due Process: The requirement for an open and fair hearing, including the opportunity to confront witnesses and present evidence, in disciplinary proceedings against judges.

3. Judicial Integrity and Impartiality: The expectations and standards set out in the Code of Judicial Conduct that judges must avoid impropriety and perform duties with impartiality and diligence.

4. Prohibition of Entrapment Methods: The disapproval of instigation or improper entrapment methods by law enforcement in securing evidence against individuals, especially in the judicial context.

5. Preservation of Judicial Reputation and Independence: The importance of protecting judges from unlawful and unfounded accusations to maintain public confidence in the judicial system.