Facts
The case originated from a social media post alleging improper conduct by a Marikina Regional Trial Court judge, later identified as Judge Rey P. Inciong, which prompted the Office of the Court Administrator (OCA) to initiate an administrative complaint. The incident stemmed from events on March 9, 2023, when Atty. Ivanheck Gatdula, a Public Attorney’s Office (PAO) lawyer, briefly parked his vehicle near a PWD access ramp at the Justice Hall of Marikina to clock in using the biometrics system. Upon noticing the obstruction, Judge Inciong confronted Atty. Gatdula in the lobby, where he publicly berated him using harsh and demeaning language despite the latter’s repeated apologies. The judge questioned his conduct, insulted him, and demanded that he issue a public apology for the inconvenience caused.
Later that same day, Judge Inciong proceeded to the PAO office and again confronted Atty. Gatdula and his superior, Atty. Rodaflor Larracas. During this second encounter, the judge continued his tirade, reiterated his demand for a public apology, and acted in an aggressive and intimidating manner by invading Atty. Gatdula’s personal space. Witnesses, including court personnel and security guards, corroborated that the judge raised his voice, uttered offensive remarks, and caused a scene in both instances.
In his explanation, Judge Inciong admitted that he lost his temper and used harsh words but maintained that his actions were motivated by his desire to enforce order and prevent obstruction of the PWD access ramp, which inconvenienced court users. He apologized for his behavior and attributed his outburst to stress and the pressures of his duties. Meanwhile, the OCA and the Judicial Integrity Board recommended that he be sanctioned for vulgar and unbecoming conduct, as well as for using offensive language, based on the established facts and witness accounts.
ISSUE: Whether Judge Rey P. Inciong should be held administratively liable for vulgar, unbecoming conduct and use of offensive language.
Ruling
The Supreme Court did not impose any administrative liability; however, the judge was admonished.
The Supreme Court held that Judge Rey P. Inciong should not be held administratively liable, although his conduct warranted caution. While the Court agreed with the factual findings that respondent used harsh, demeaning, and intemperate language and acted in an intimidating manner, it found that his actions were motivated by a legitimate concern—namely, the need to prevent obstruction of a PWD access ramp and to maintain order within court premises. Taking into account that this was his first offense and that he had an otherwise unblemished record in public service, the Court exercised leniency and refrained from imposing administrative penalties. Instead, it admonished him to be more circumspect in his conduct and warned that a repetition of similar acts would be dealt with more severely.
In reaching this conclusion, the Court reiterated well-established jurisprudence emphasizing judicial decorum and restraint. It cited earlier decisions as guideposts, stressing that judges must at all times exhibit courtesy, patience, and propriety in both conduct and language. In Spouses Jacinto v. Judge Vallarta, the Court underscored that the use of intemperate language diminishes respect for the judiciary and erodes public confidence. Similarly, in Tormis v. Judge Paredes, it held that while judges enjoy freedom of expression, they must exercise it in a manner that preserves the dignity of judicial office. In Judge Misajon v. Feranil, the Court ruled that even in disciplining subordinates, judges must avoid offensive or humiliating language. Finally, in Re: Anonymous Complaint Against Judge Edmundo T. Acuña, the Court declared that even casual use of profanities is unacceptable for members of the bench, as they are subject to constant public scrutiny, and as such, the respondent judge was reminded to always “exhibit conduct consistent with dignity of the judicial office.” Guided by these precedents, the Court acknowledged that although respondent’s objective was valid, his manner of enforcement was disproportionate and improper, thus necessitating an admonition.