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ATTY. MELVIN D.C. MANE v. JUDGE MEDEL ARNALDO B. BELEN

FACTS:

Judge Medel Arnaldo B. Belen (respondent), Presiding Judge of Branch 36, Regional Trial Court, Calamba City, was charged with "demeaning, humiliating, and berating" Atty. Melvin D.C. Mane (complainant) during a hearing on February 27, 2006, in Civil Case No. 3514-2003-C, "Rural Bank of Cabuyao, Inc. v. Samuel Malabanan, et al," where the complainant was the counsel for the plaintiff. The complainant provided a transcript of stenographic notes taken during the said hearing, which captured the remarks made by the respondent. The respondent questioned the complainant's alma mater, implying that the complainant's law school was inferior to the University of the Philippines. The complainant later withdrew his complaint, stating it was a result of his impulsiveness.

The Office of the Court Administrator (OCA) found that the respondent's conduct fell below the standard of decorum expected of a judge and recommended that he be reprimanded for violating Canon 3 of the Code of Judicial Conduct. The OCA also warned that a repetition of the same conduct would be dealt with more severely. The Code of Judicial Conduct requires judges to be patient, attentive, and courteous to lawyers, litigants, witnesses, and others appearing before the court. It is important for judges to act and behave in a manner that inspires confidence in their impartiality.

Transcript of stenographic notes from the hearing showed that the respondent judge made sarcastic, humiliating, threatening, and boastful remarks to the complainant, who is a young lawyer. The respondent judge asked about the complainant's school and engaged in unnecessary display of learning. The OCA noted that the withdrawal of the complaint will not bar the continuity of the administrative proceeding against the respondent. The issue presented was whether the statements and actions made by the respondent during the hearing constituted conduct unbecoming of a judge and a violation of the Code of Judicial Conduct. The OCA found that the respondent's insulting remarks were unwarranted and inexcusable and emphasized the importance of judges observing courtesy and civility in their conduct and language.

ISSUES:

  1. Whether respondent judge's remarks to complainant lawyer during the hearing were sarcastic, humiliating, threatening, and boastful.

  2. Whether respondent judge's remarks violated the Code of Judicial Conduct.

  3. Whether the three-day notice rule should be strictly followed.

  4. Whether the lawyer’s motion should be granted despite non-compliance with the three-day notice rule.

  5. Whether or not the judge's reliance on the lawyer's alma mater in determining his competence is valid.

  6. Whether or not the judge's conduct during the proceedings was unbecoming of a judge.

RULING:

  1. Yes, respondent judge's remarks to complainant lawyer were sarcastic, humiliating, threatening, and boastful, as evidenced by the transcript of stenographic notes.

  2. Yes, respondent judge's remarks violated the Code of Judicial Conduct. Judges are expected to conduct themselves in a manner that promotes public confidence in the integrity and impartiality of the judiciary. Respondent judge's remarks were disrespectful and breached the duty to maintain proper decorum and respect towards the parties and lawyers involved.

  3. The court ruled that the three-day notice rule should be strictly followed. Non-compliance with this rule renders the pleading and motion a useless scrap of paper. In this case, the lawyer failed to comply with the three-day notice rule, thus his motion cannot be granted.

  4. The judge's reliance on the lawyer's alma mater in determining his competence is not valid. The Supreme Court emphasized that a lawyer who has passed the Bar Examinations, taken the Lawyer's oath, and signed the Roll of Attorneys is presumed to be competent to discharge his functions as an officer of the court, regardless of where he obtained his law degree. The judge's engagement in an argumentum ad hominem is a clear violation and misjudgment of the lawyer's competence solely based on his alma mater.

  5. The judge's conduct during the proceedings was unbecoming of a judge. Although the judge acted properly by directing the lawyer to explain why he should not be cited for contempt, he went over the line by engaging in a supercilious and offensive legal and personal discourse. The Supreme Court reminded judges to conduct themselves in a manner befitting gentlemen and high officers of the court, even when faced with boorish behavior from those they deal with.

PRINCIPLES:

  • Judges are expected to conduct themselves with utmost propriety and take care to avoid making any remarks that may be considered demeaning or humiliating.

  • Judges should promote public confidence in the judiciary by maintaining decorum and respect towards parties and lawyers involved in court proceedings.

  • Lawyers are entitled to be treated with respect and courtesy by judges and should not be subjected to sarcastic or humiliating remarks.

  • Judges should exercise caution and professionalism in order to enforce due diligence in the dispatch of business before the court.

  • The three-day notice rule requires parties to provide a three-day notice before filing a motion. Failure to comply with this rule renders the pleading and motion useless.

  • Procedural due process requires parties to be given notice and an opportunity to be heard. This includes complying with the three-day notice rule to give the other party time to appear and plead.

  • A lawyer who has passed the Bar Examinations and fulfilled the necessary requirements to become an attorney is presumed to be competent to discharge his duties, regardless of his alma mater.

  • Judges should address the merits of a case and not judge the person based on their alma mater or personal characteristics.

  • Judges should conduct themselves in a manner befitting gentlemen and high officers of the court, even when faced with boorish behavior from those they deal with.