ANONYMOUS, COMPLAINANT, VS. HON. JACINTO M. DELA CRUZ, JR., PRESIDING JUDGE, BRANCH 81, REGIONAL TRIAL COURT, ASINGAN, PANGASINAN, RESPONDENT.

Anonymous versus Judge Dela Cruz

The Case

This is an administrative case against Judge Jacinto M. Dela Cruz, Jr., then presiding judge of Branch 33 of the Regional Trial Court in Bauang, La Union, and later of Branch 81 of the Regional Trial Court in Asingan, Pangasinan. It began with an anonymous letter complaining that he promulgated decisions online by reading only the dispositive portions, and released the hard copies of the full decisions only several months later. The case matters because it fixes the line between simple misconduct and gross misconduct in judicial discipline, and because it tells us how the Court weighs humanitarian considerations, remorse, and the realities of the pandemic years when it imposes a penalty.

Procedural History

The anonymous letter, dated July 5, 2022, reached the Complaints Docket Services of the Judicial Integrity Board. The Board's Office of the General Counsel recommended that the matter be referred to the Office of the Court Administrator for investigation and report. An investigation team of the Office of the Court Administrator conducted a spot audit and investigation of Branch 33 from July 3 to 7, 2023, and recommended that the letter be treated as a formal administrative complaint. The team found gross inefficiency and gross neglect of duty, violation of Article VIII, Section 14 of the Constitution, utter disregard of court procedure, and false statements in the certificates of service, and recommended charges of gross misconduct and falsification of official documents. The Judicial Integrity Board directed the judge to comment, and he filed a verified comment admitting the lapses. In its Report and Recommendation dated November 4, 2025, the Board recommended dismissal from the service with forfeiture of benefits, disqualification from government employment, and a fine of 51,000 pesos for gross misconduct as a member of the Bar. The case was resolved by the Supreme Court En Banc as an administrative matter, with the Court applying the 2025 Code of Judicial Conduct and Accountability, which took effect on December 21, 2025.

Facts

During the peak of the COVID-19 pandemic, from 2020 to 2022, Judge Dela Cruz conducted hearings and promulgated judgments through videoconferencing. Before promulgation, he would ask counsel whether the judgment would be read in full or only through its dispositive portion, and most of the time counsel opted for the dispositive portion only. When the judgment was an acquittal, he made sure that the person deprived of liberty was released on the same day of promulgation. Because the judgment had been promulgated online, the clerk of court would record in the monthly report that the case was already decided or disposed of.

What the anonymous letter exposed was the other side of the practice. The hard copies of the full decisions were released only three to eleven months after promulgation, and some were antedated to make it appear that they had been decided within the ninety-day reglementary period. The branch clerk of court confirmed that hard copies were belatedly furnished to litigants, and that at least twenty-one case records were still in the possession of the judge, who had brought them home. The Office of the Court Administrator concluded that he had knowingly circumvented the mandatory period and had made false statements in his certificates of service for March, June, August, and October 2022.

In his verified comment, the judge admitted the lapses, asking pardon, and explained that he needed additional time for proofreading and editing. He had no legal researcher for five years, he contracted COVID-19 twice in 2023, his sister who cared for their ill mother became paralyzed, and both his parents passed away in 2022. He stressed that all hard copies had since been released, that motions for reconsideration were timely resolved, and that he had no backlog in his current docket.

Issues

• Whether or not the judge is liable for gross misconduct, gross inefficiency, and falsification of official documents for promulgating decisions by reading only their dispositive portions and releasing the hard copies months later.
• Whether or not his acts amount to simple misconduct only, absent corruption, clear intent to violate the law, or flagrant disregard of an established rule.
• Whether or not he is liable for gross misconduct as a member of the Philippine Bar for false representations under the Code of Professional Responsibility and Accountability.
• Whether or not the penalty of fine at half of the minimum prescribed may be imposed in view of mitigating circumstances.

Applicable Provisions

Article VIII, Section 14 of the Constitution provides:

No decision shall be rendered by any court without expressing therein clearly and distinctly the facts and the law on which it is based.

This is the constitutional standard that the online promulgation of dispositive portions alone was measured against.

Canon VII, Section 19 of the 2025 Code of Judicial Conduct and Accountability provides:

Less serious offenses include: (a) Simple misconduct constituting violations of this Code, the Code of Conduct and Ethical Standards for Public Officials or Employees, or the Code of Professional Responsibility and Accountability.

This is the provision under which the Court ultimately classified the judge's infraction.

Canon VII, Section 22 of the same Code provides:

If the respondent is found guilty of a less serious offense, any of the following penalties shall be imposed: (a) Suspension from office without salary and other benefits for no less than one month nor more than six months and one day up to one year; and/or (b) A fine of 51,000 pesos but not more than 100,000 pesos.

This fixes the range from which the fine was drawn.

Canon VII, Section 24 of the same Code provides:

In determining the appropriate penalty to be imposed, the Court may, in its discretion, appreciate the following mitigating and aggravating circumstances: 1. Mitigating circumstances: First offense; Length of service of at least ten years with no previous disciplinary case where respondent was meted with an administrative penalty; Exemplary performance; Humanitarian considerations; Unconditional admission of guilt and public demonstration of remorse; and Other analogous circumstances.

This allowed the Court to reduce the fine on account of his admission, remorse, and the pandemic circumstances.

Canon VII, Section 25 of the same Code provides:

If one or more aggravating circumstances and no mitigating circumstances are present, the Supreme Court may impose the penalties of suspension or fine, for a period or amount not less than half of the minimum prescribed under this Canon.

This is the rule the Court applied in imposing a fine of half the minimum.

Canon II, Section 11 of the Code of Professional Responsibility and Accountability provides:

A lawyer shall not make false representations or statements. A lawyer shall be liable for any material damage caused by such false representations or statements.

This was the basis of the Bar charge, which the Court dismissed.

Ruling

On the first issue, the Court held that the judge's acts were not tainted with corruption, clear intent to violate the law, or flagrant disregard of an established rule, which are the elements that raise simple misconduct to gross misconduct. It acknowledged its disapproval of judgments that state no facts, but gave leeway for videoconference hearings during the peak of the pandemic, absent any showing of malice, with a strong warning that it must never happen again.

On the second issue, the Court ruled that the belated furnishing of hard copies long after promulgation is simple misconduct. It noted that he ensured acquitted persons deprived of liberty were released on the same day, that all hard copies had been released, that no accused was denied the right to appeal or to move for reconsideration, and that he had no backlog. On the certificates of service, the Court reminded that they must faithfully reflect the real docket and accomplishments.

On the third issue, the Court dismissed the Bar charge for lack of merit.

On the fourth issue, applying the mitigating circumstances of first offense, exemplary performance, humanitarian considerations, unconditional admission of guilt, and remorse, the Court imposed a fine of 25,500 pesos, or half of the minimum prescribed.

Doctrine

Misconduct is a transgression of some established and definite rule of action, more particularly unlawful behavior or gross negligence by the public officer. To be gross, any of the elements of corruption, clear intent to violate the law, or flagrant disregard of an established rule must be manifest. Absent those elements, the infraction is simple misconduct, a less serious offense under Canon VII, Section 19 of the 2025 Code of Judicial Conduct and Accountability. In administrative proceedings the quantum of proof is substantial evidence, that amount of relevant evidence a reasonable mind might accept as adequate to support a conclusion. Mitigating circumstances under Canon VII, Section 24, such as a first offense, exemplary performance, humanitarian considerations, and unconditional admission of guilt with remorse, may reduce the penalty, and under Canon VII, Section 25 a fine of half the minimum may be imposed.

Disposition

The Court found Judge Dela Cruz liable for simple misconduct and fined him 25,500 pesos, payable within three months from notice, and dismissed the charge of gross misconduct as a member of the Philippine Bar.

Remember This

Memorize the triad: corruption, clear intent to violate the law, or flagrant disregard of an established rule, and without any of them the misconduct is only simple. Examiners use this case to test the distinction between simple and gross misconduct and the appreciation of mitigating circumstances in judicial discipline.