ENRIQUETA GARGAR DE JULIO v. JUDGE BENJAMIN A.G. VEGA

FACTS:

Enriqueta Gargar de Julio filed a complaint against Judge Benjamin A.G. Vega, formerly of the City Court of Olongapo City and now of the Regional Trial Court in Manila, charging him with conduct unbecoming a judge. The complaint is based on Judge Vega's failure to pay his rental obligations for a building he leased from the complainant. The records show that in 1977, Judge Vega and his wife leased the complainant's building where they operated a bake shop and hot pandesal business. They initially paid the rent regularly but defaulted in July 1977. The complainant made verbal demands for payment, but the lessees did not comply. A demand letter was sent to them on November 25, 1977. When the Vegas failed to settle their rental obligations, an ejectment complaint was filed against them in 1978. The trial lasted for ten years due to Judge Vega's dilatory tactics, and judgment was rendered in 1987 ordering the defendants to pay the plaintiffs the sum of P2,500 representing unpaid rentals. The judgment was affirmed by the Regional Trial Court and the Court of Appeals. However, Judge Vega continuously delayed the execution of the judgment, and it was only after the complainant filed an administrative case against him that he paid the amount due. The Court finds Judge Vega guilty of oppressive conduct and willful delay in paying a just debt and imposes a fine of P20,000.

ISSUES:

  1. Whether Judge Benjamin A.G. Vega's conduct constitutes conduct unbecoming a judge.

  2. Whether Judge Vega's failure to pay a just debt and his delay in doing so warrant disciplinary action.

RULING:

  1. Yes, Judge Benjamin A.G. Vega's conduct constitutes conduct unbecoming a judge. He used his position and legal knowledge to evade and delay the payment of a just debt, frustrating the complainant's efforts to obtain satisfaction of her lawful claim. He violated Rule 2.01, Canon 2 of the Code of Judicial Conduct which requires judges to behave in a manner that promotes public confidence in the integrity and impartiality of the judiciary.

  2. Yes, Judge Vega's failure to pay a just debt and his delay in doing so warrant disciplinary action. Willful failure to pay a just debt is considered a serious offense under Rule 140 of the Rules of Court. Judge Vega's conduct erodes public faith in the capacity of courts to administer justice. He is therefore ordered to pay a fine of Twenty Thousand Pesos (P20,000) and is warned that a repetition of this misconduct in the future will be dealt with more severely.

PRINCIPLES:

  • Judges should conduct themselves at all times to promote public confidence in the integrity and impartiality of the judiciary. (Rule 2.01, Canon 2 of the Code of Judicial Conduct)

  • Willful failure to pay a just debt is considered a serious offense. (Rule 140 of the Rules of Court)