The Supreme Court ruled that Judge Policarpio S. Camano, Jr. was guilty of serious misconduct and violation of the Code of Judicial Conduct for maintaining a scandalous relationship with a woman not his wife for over two decades and siring a child with her. Even though Judge Camano had retired, the Court imposed a fine of Twenty Thousand Pesos (P20,000.00), asserting that retirement does not shield a judge from administrative liability for actions committed during their service. This decision underscores the high standard of morality and decency expected of judges, both in their official duties and private lives, to maintain public confidence in the integrity and impartiality of the judiciary.

When the Gavel Falls: A Judge’s Double Life and the Price of Impropriety

This case arose from a complaint filed by Asuncion S. Liguid against Judge Policarpio S. Camano, Jr., accusing him of abandonment, dishonesty, oppression, deceit, immorality, and misconduct in office. Liguid claimed that she and Judge Camano had a long-term romantic relationship, during which they lived together as husband and wife and had a child. The central legal question revolved around whether Judge Camano’s conduct, specifically his relationship with Liguid, constituted a violation of the Code of Judicial Conduct and warranted administrative sanctions, despite his subsequent retirement.

The complainant, Asuncion S. Liguid, detailed a history of a romantic relationship with Judge Camano that spanned over two decades. Liguid asserted that Judge Camano reneged on his promise to marry her and support their child, Joanne. Further, she accused him of maintaining illicit relations with other women and of various acts of misconduct, including unauthorized absences from work. In response, Judge Camano vehemently denied the charges, arguing that Liguid knew from the beginning of their relationship that he was married and that he had provided for Joanne’s basic necessities. He also refuted the claims of misconduct, presenting evidence of his accomplishments as a judge and testimonials attesting to his integrity. Despite his retirement, the Court proceeded with the administrative case to determine his liability for the alleged misconduct.

The Supreme Court, in its analysis, emphasized the high ethical standards expected of members of the judiciary. Citing Canon 2, Rule 2.01 of the Code of Judicial Conduct, the Court reiterated that a judge should avoid impropriety and the appearance of impropriety in all activities, behaving at all times in a manner that promotes public confidence in the integrity and impartiality of the judiciary. The Court found substantial evidence of Judge Camano’s misconduct, including sworn statements from individuals who attested to his cohabitation with Liguid and documentary evidence that contradicted his claim that he distanced himself from her upon being appointed to the judiciary. Even testimonials from other individuals were deemed self-serving, considering the moral ascendancy a judge would have over them.

The Court addressed the argument that Judge Camano’s relationship with Liguid occurred before his appointment to the judiciary. However, the evidence demonstrated that the relationship continued well into his tenure as a judge, thus constituting a violation of the Code of Judicial Conduct. In administrative proceedings, the standard of substantial evidence is satisfied when there is reasonable ground to believe that the respondent is responsible for the misconduct complained of, even if such evidence might not be overwhelming or even preponderant. The Supreme Court stated that:

Substantial evidence is that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. The standard of substantial evidence is satisfied *when there is reasonable ground to believe* that respondent is responsible for the misconduct complained of, even if such evidence might not be overwhelming or even preponderant.

The Court underscored that the cessation from office due to retirement does not warrant the dismissal of an administrative complaint filed while the respondent was still in service. Jurisdiction that was this Court’s at the time of the filing of the administrative complaint is not lost by the mere fact that the respondent public official had ceased in office during the pendency of his case. This principle ensures that erring members of the judiciary cannot escape accountability by simply resigning or retiring.

Regarding the procedural aspect of the case, the complainant’s request to testify was denied, as she had already been given adequate opportunity to present her side through pleadings. The Supreme Court emphasized that due process in administrative proceedings does not necessarily require a hearing but simply a reasonable opportunity to be heard. The essence of due process is an opportunity to explain one’s side.

The Court highlighted the importance of maintaining the integrity of the judiciary and ensuring public trust in the judicial system. Given the gravity of Judge Camano’s misconduct, which involved living openly and scandalously with a woman not his wife for over two decades and fathering a child with her, the Court found him guilty of serious misconduct and violation of the Code of Judicial Conduct. The Court acknowledged that had Judge Camano not retired, his actions would have warranted the penalty of dismissal. However, in light of his retirement, the Court imposed a fine of Twenty Thousand Pesos (P20,000.00).

This ruling underscores the importance of upholding the highest ethical standards within the judiciary. It clarifies that retirement does not shield judges from administrative liability for misconduct committed during their tenure. The decision serves as a reminder that judges must maintain impeccable behavior both in their official and private lives to preserve public confidence in the judicial system.

FAQs

What was the key issue in this case?	The key issue was whether Judge Camano’s relationship with a woman not his wife constituted a violation of the Code of Judicial Conduct and warranted administrative sanctions, despite his retirement. The Court examined if the judge’s actions undermined the integrity and public trust in the judiciary.
What constitutes substantial evidence in administrative cases?	Substantial evidence is that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. It means there is a reasonable basis to believe the respondent is responsible for the misconduct, even if the evidence is not overwhelming.
Does retirement shield a judge from administrative liability?	No, retirement does not shield a judge from administrative liability for actions committed during their service. The Court retains jurisdiction to resolve administrative complaints filed against officials even after they have left office.
What standard of conduct is expected of judges?	Judges are expected to observe an exacting standard of morality and decency, with their private and official conduct free from all appearances of impropriety. They must uphold the integrity and impartiality of the judiciary at all times.
What is the significance of Canon 2 of the Code of Judicial Conduct?	Canon 2 mandates that a judge should avoid impropriety and the appearance of impropriety in all activities. Rule 2.01 further specifies that a judge should behave at all times to promote public confidence in the integrity and impartiality of the judiciary.
Why was the complainant’s request to testify denied?	The complainant’s request to testify was denied because she had already been given more than adequate opportunity to explain her side through pleadings. The Court emphasized that due process in administrative proceedings does not necessarily require a hearing.
What was the penalty imposed on Judge Camano?	The Supreme Court found Judge Camano guilty of Serious Misconduct and Violation of the Code of Judicial Conduct and imposed on him a FINE of Twenty Thousand Pesos (P20,000.00). This was due to the judge’s retirement; otherwise, a more severe penalty would have been imposed.
What does this case teach us about judicial ethics?	This case underscores the importance of upholding high ethical standards in the judiciary and ensures public trust in the legal system. It serves as a reminder that judges must maintain impeccable behavior both in their official and private lives.

The Supreme Court’s decision in this case serves as a significant reminder to all members of the judiciary that their conduct, both on and off the bench, is subject to scrutiny and must adhere to the highest ethical standards. It reinforces the principle that public confidence in the judiciary is paramount and that any behavior that undermines this confidence will be met with appropriate sanctions.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Asuncion S. Liguid vs. Judge Policarpio S. Camano, Jr., A.M. No. RTJ-99-1509, August 08, 2002