Lachica v. Flordeliza

A.M. No. MTJ-94-921 (March 5, 1996)

Dr. Lachica accused Judge Flordeliza of misconduct, fined ₱10,000 for ethical violations.

Facts:

Dr. Amparo A. Lachica, the Municipal Health Officer of Jose Abad Santos, Davao del Sur, filed an Affidavit-Complaint against Judge Rolando A. Flordeliza of the Municipal Circuit Trial Court, alleging abuse of judicial position and intimidation. The complaint arose from an incident on August 12, 1993, when Dr. Lachica was approached by two women, Dina Masaglang and Norma Puton, who insisted that she sign a death certificate for Hilario Kiawan, despite her not being the attending physician. Dr. Lachica refused, explaining that the attending physician from General Santos City should sign the certificate instead.

Later that evening, during a Municipal Employees Night Party, Judge Flordeliza, who was reportedly intoxicated, confronted Dr. Lachica about her refusal to sign the death certificate. He allegedly threatened her with an administrative case if she did not comply. The following day, the same women approached Dr. Lachica again, but she reiterated her refusal to sign the document.

In response, Judge Flordeliza denied the allegations, claiming he did not order the women to pressure Dr. Lachica and that he had no personal interest in the matter. He asserted that he was not drunk during their conversation and that his inquiries were made in good faith. He also provided affidavits from witnesses to support his claims.

The case was referred to Judge Magno C. Cruz for investigation, who submitted a report based on the evidence presented by both parties. The investigating judge found substantial evidence supporting Dr. Lachica's claims and recommended that Judge Flordeliza be held administratively liable.

Legal Issues:

The primary legal issue in this case was whether Judge Flordeliza was guilty of misconduct, specifically abuse of judicial position and intimidation, in violation of the Code of Judicial Conduct. The resolution of this issue hinged on the credibility of the parties involved and the evidence presented.

Arguments:

  • Complainant's Arguments: Dr. Lachica argued that Judge Flordeliza improperly pressured her to sign a death certificate for a case in his court, despite her lack of involvement as the attending physician. She maintained that his behavior during the party was intimidating and that his threats of administrative action were inappropriate. She also pointed out inconsistencies in Judge Flordeliza's account and provided affidavits from credible witnesses, including the Mayor, to support her claims.

  • Respondent's Arguments: Judge Flordeliza denied all allegations, asserting that he did not coerce Dr. Lachica and had no personal interest in the matter. He claimed that the conversation was casual and that he was not intoxicated at the time. He argued that the complainant's accusations were implausible and that the witnesses he presented corroborated his version of events.

Court's Decision and Legal Reasoning:

The court found that the evidence presented by Dr. Lachica was credible and substantial, leading to the conclusion that Judge Flordeliza had indeed engaged in misconduct. The court emphasized the importance of maintaining the integrity and independence of the judiciary, as outlined in Canons 1 and 2 of the Code of Judicial Conduct. The court noted that a judge's conduct must be beyond reproach, both in official duties and personal behavior.

The court highlighted that Judge Flordeliza's undue interest in the death certificate was questionable and that his behavior during the party, particularly his intoxication, was unbecoming of a judge. The court reiterated that judges must not only avoid impropriety but also the appearance of impropriety in all their activities.

As a result, the court held Judge Flordeliza administratively liable for violating the Code of Judicial Conduct and imposed a fine of P10,000, along with a stern warning against future misconduct.

Significant Legal Principles Established:

  1. Integrity of the Judiciary: Judges must uphold the integrity and independence of the judiciary, ensuring their conduct is beyond reproach.
  2. Avoidance of Impropriety: Judges are required to avoid not only actual impropriety but also the appearance of impropriety in all their activities.
  3. Credibility in Administrative Cases: The resolution of administrative cases often hinges on the credibility of the parties involved and the evidence presented.