**Facts:**
1. Assistant Special Prosecutor III Rohermia J. Jamsani-Rodriguez filed an affidavit-complaint against Sandiganbayan Justices Gregory S. Ong, Jose R. Hernandez, and Rodolfo A. Ponferrada on October 23, 2008.
2. The charges against the justices, who were members of the Fourth Division, included grave misconduct, conduct unbecoming a justice, and conduct grossly prejudicial to the interest of the service. Specific allegations were made:
– The justices were accused of failing to hear cases as a collegial body during sessions in Davao City (April 24-28, 2006), where Justice Ong heard cases alone while Hernandez and Ponferrada heard others together.
– They allegedly falsified public documents by signing orders to make it appear they sat as a collegiate body during hearings when they did not.
– Justice Ong and Justice Hernandez were accused of making intemperate and discriminatory utterances during hearings in Cebu City in September 2006.
– Manifest partiality and gross ignorance of the law were alleged due to their dismissal of Criminal Case No. 25801 on a demurrer to evidence, contrary to the prosecution’s evidence.
3. On August 24, 2010, the Supreme Court found Justices Ong and Hernandez liable for simple misconduct, penalizing Ong with a P15,000 fine and a warning. Justice Hernandez was admonished with a warning, while Ponferrada was cautioned about procedural adherence.
4. Both Justices Ong and Hernandez and complainant Jamsani-Rodriguez filed motions for reconsideration of the decision rendered on August 24, 2010, requesting reconsideration on different grounds.
**Issues:**
1. Whether the conduct of Justices Ong and Hernandez during the provincial hearings constituted simple misconduct or unbecoming conduct.
2. Whether the justices’ signing of the orders related to hearings constituted falsification or dishonesty.
3. Whether the alleged utterances made by Justices Ong and Hernandez indicated unbecoming conduct.
4. The appropriateness of the penalty imposed on Justice Ong compared to Justice Hernandez, given their respective positions and responsibilities within the Sandiganbayan.
**Court’s Decision:**
– **Simple Misconduct:** The Supreme Court held that the procedure adopted by the justices during provincial hearings did not conform to legal and procedural standards. However, it was classified as simple misconduct rather than gross misconduct, as no malicious intent or persistence in error was established.
– **Unbecoming Conduct:** The court affirmed the lack of evidence for the alleged utterances, thus clearing Justices Ong and Hernandez of those specific charges. However, it still found their behavior, such as discussing law school affiliations, as lacking in judicial decorum, highlighting a failure in displaying appropriate judicial temperament.
– **Lack of Falsification/Dishonesty:** The court did not consider the signing of orders as falsification, as it stemmed from procedural errors rather than intentional deceit.
– **Differentiated Penalties:** The court justified the distinct penalties based on Justice Ong’s higher responsibility as Chairperson, which warranted a more severe response for steering the proceedings toward irregularity, unlike Justice Hernandez, who acted under Ong’s direction.
**Doctrine:**
– **Collegial Decision Making:** The case underscores the importance of collectively conducting judicial proceedings in a collegial court, such as the Sandiganbayan, where decisions must reflect the involvement and consensus of all assigned justices.
**Class Notes:**
– **Simple Misconduct vs. Gross Misconduct:** Simple misconduct involves improper behavior without malicious intent, distinguished from gross misconduct that implies intentional wrongdoing.
– **Judicial Decorum:** Justices must maintain professionalism in judicial settings, refraining from behaviors that may denote bias or favoritism.
– **Collegial Bodies’ Operation:** Judicial proceedings in a collegial body require the active participation and decision-making authority of all members, emphasizing transparency and joint accountability.
**Historical Background:**
– The case reflects challenges within the Philippine judiciary over maintaining procedural integrity and ensuring adherence to judicial decorum amidst pressures to expedite case hearings. The balancing act between efficiency and procedural propriety is highlighted, as well as the internal checks and balances within the judiciary to uphold standards amidst allegations of misconduct.
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