**Facts:**
During a Supreme Court En Banc session on July 15, 2008, Justice Ruben T. Reyes circulated his draft decision (ponencia) in the consolidated cases involving Limkaichong v. COMELEC et al. The Justices initially approved the draft, but later decided to withhold its promulgation upon realizing that a majority only concurred “in the result,” potentially diminishing its doctrinal value. It was unanimously decided to conduct oral arguments on August 26, 2008. Despite this, Louis Biraogo, a petitioner in one of the cases, conducted a press conference on December 9, 2008, releasing an undated letter and a copy of the yet-to-be promulgated ponencia, raising issues of unauthorized disclosure of a confidential Court document. This prompted the Supreme Court to form an Investigating Committee to determine responsibility for the leakage.
**Issues:**
1. Who was responsible for the unauthorized release of Justice Reyes’s unpromulgated ponencia?
2. Did the release of the unpromulgated ponencia constitute a breach of internal Court confidentiality and contempt of court?
3. What administrative liabilities, if any, arise from the unauthorized release of the ponencia?
**Court’s Decision:**
The Investigating Committee, after exhaustive hearings and examination of evidence, found substantial circumstantial evidence pointing to Justice Ruben T. Reyes as the source of the leak, thus engaging in Grave Misconduct. The Committee also found Atty. Rosendo B. Evangelista and Armando Del Rosario liable for Simple Neglect of Duty for failing in their respective responsibilities regarding the custody and promulgation process of Court decisions.
**Doctrine:**
The unauthorized release of confidential internal Court documents constitutes Grave Misconduct due to its detrimental effects on the Court’s integrity and the fair administration of justice. Moreover, Simple Neglect of Duty applies to court personnel failing to appropriately manage and secure such documents.
**Class Notes:**
1. **Grave Misconduct:** Involves acts of wrongdoing constituting a serious breach of conduct by a court official or employee that directly affects the execution of their duties, potentially undermining the integrity and proper function of the judiciary.
2. **Simple Neglect of Duty:** Pertains to the failure of court personnel to perform their duty out of carelessness or indifference, potentially compromising the confidentiality and security of Court documents.
3. **Confidentiality Internal Court Documents:** Underlines the principle that all draft decisions, deliberations, and related internal documents are considered confidential until officially promulgated or released by authorized Court personnel.
**Historical Background:**
This case underscores the vital importance of maintaining confidentiality in the judiciary’s internal deliberations and documents. It reflects the challenges the Court faces in securing internal processes and highlights the need for strict protocols to prevent unauthorized disclosures that can undermine public confidence in the judicial system.
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