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., presiding judge of Branch 81 of the Regional Trial Court of Asingan, Pangasinan, arising from an anonymous letter that accused him of promulgating decisions online by reading only their dispositive portions and then releasing the hard copies of the full decisions several months later. The case matters because it is the Supreme Court's first extended application of the 2025 Code of Judicial Conduct and Accountability to a sitting judge, and because it draws the line between simple misconduct and gross misconduct in the context of delayed and defective promulgation of judgments.

Procedural History

The anonymous letter, dated July 5, 2022, was received by the Complaints Docket Services of the Judicial Integrity Board. The Board's Office of the General Counsel recommended referral to the Office of the Court Administrator for investigation and report. An investigation team conducted a spot audit and investigation of Branch 33 of the Regional Trial Court of Bauang, La Union from July 3 to 7, 2023, and recommended that the letter be treated as a formal administrative complaint. The investigation 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 Judicial Integrity Board recommended a finding of gross misconduct, falsification of official documents, and gross misconduct as a member of the Philippine Bar, with dismissal from the service and a fine of 51,000 pesos. The case then came before the Supreme Court as an original administrative matter.

Facts

During the peak of the COVID-19 pandemic, from 2020 to 2022, Judge Dela Cruz, Jr. conducted hearings and promulgated judgments through videoconferencing. Before promulgation, he asked counsel how the judgment should be promulgated, whether in full text or by dispositive portion only, and most of the time counsel opted for the reading of the dispositive portion alone. When the judgment was an acquittal, he ordered the immediate release of the person deprived of liberty on the same day of promulgation, at the latest.

However, the hard copies of the complete decisions were released only three to eleven months after promulgation, and some were antedated to make it appear that they were decided within the ninety-day reglementary period. The branch clerk of court confirmed that hard copies were belatedly furnished to party-litigants, and that at least twenty-one case records were still in the possession of the judge as of July 4, 2023. The judge certified in his monthly certificates of service that he had decided all his cases for March, June, August, and October 2022 within three months from submission.

In his verified comment, the judge admitted the lapses on bended knees but explained that he needed additional time for proofreading and editing because he had no legal researcher for five years, that he contracted COVID-19 twice in 2023, that his sister who cared for their ill mother became physically paralyzed, and that both his parents passed away in 2022. He also stated that the hard copies had already been released, that motions for reconsideration were timely resolved, and that he had no backlogs in his current docket.

Issues

• Whether or not Judge Dela Cruz, Jr. is administratively liable for gross misconduct, falsification of official documents, and gross misconduct as a member of the Philippine Bar.
• Whether or not his acts constitute simple misconduct under the 2025 Code of Judicial Conduct and Accountability.
• Whether or not the charge of gross misconduct as a member of the Philippine Bar under the Code of Professional Responsibility and Accountability should be dismissed.

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 provision is the standard the Court measures the judge's promulgation practice against, since a decision read only through its dispositive portion does not express the facts and the law on which it is based.

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 provision classifies the offense the Court ultimately attributes to the judge.

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 PHP 51,000.00 but not more than PHP 100,000.00.

This provision supplies the range from which the Court fixes the fine.

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 provision authorizes the Court to lower the penalty on account of the judge's remorse, admission, and the humanitarian circumstances he cited.

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 provision governs the manner of imposing the reduced fine in this case.

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 provision is the basis of the charge of gross misconduct as a member of the Philippine Bar, which the Court dismisses.

Ruling

On the first issue, the Court holds that the judge is not liable for gross misconduct. Misconduct is a transgression of some established and definite rule of action, more particularly unlawful behavior or gross negligence by the public officer, and to be gross it must manifest corruption, clear intent to violate the law, or flagrant disregard of an established rule. The Court finds that his actions were not shown to be tainted with any of these elements. As to the promulgation of decisions online by reading only the dispositive portions, the Court notes that counsel themselves opted for this, and that the cases arose during the peak of the pandemic, so it extends leeway for humanitarian and practical considerations, but with a strong warning that it should never happen again. As to the delayed release of hard copies, the Court accepts his explanations, including the absence of a legal researcher, his illnesses, and the deaths of his parents.

On the second issue, the Court holds that the belated furnishing of hard copies of decisions long after promulgation is simple misconduct. It violates established rules, but it carries no element of corruption, clear intent to violate the law, or flagrant disregard of an established rule. The Court notes that he ensured that persons deprived of liberty who were acquitted were released on the same day of promulgation. On the certificates of service, the Court reiterates that they must faithfully reflect the real docket and accomplishments. Under Canon VII, Section 19 in relation to Sections 22, 24, and 25, the imposable fine ranges from 51,000 pesos to 100,000 pesos, and appreciating the mitigating circumstances of remorse, acknowledgment of guilt, and taking responsibility, the Court imposes a fine of 25,500 pesos, or half of the minimum prescribed penalty.

On the third issue, the Court dismisses the charge of gross misconduct as a member of the Philippine Bar under Canon II, Section 11 of the Code of Professional Responsibility and Accountability for lack of merit.

Doctrine

First, 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. Corruption consists in the act of an official or fiduciary person who unlawfully and wrongfully uses their station or character to procure some benefit for themselves or for another person, contrary to duty and the rights of others.

Second, promulgating a decision by reading only its dispositive portion, and releasing the hard copy of the full decision months later, is an undesirable practice that violates Article VIII, Section 14 of the Constitution, but without malice it is simple misconduct, not gross misconduct.

Third, certificates of service must faithfully reflect the real docket and accomplishments in accordance with the established rules of procedure.

Fourth, under the 2025 Code of Judicial Conduct and Accountability, simple misconduct is a less serious offense punishable by suspension or a fine of 51,000 pesos to 100,000 pesos, and the Court may appreciate mitigating circumstances such as first offense, exemplary performance, humanitarian considerations, and unconditional admission of guilt with public demonstration of remorse.

Fifth, in administrative proceedings the quantum of proof is substantial evidence, that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion.

Disposition

The Court found Judge Jacinto M. Dela Cruz, Jr. liable for simple misconduct and imposed on him a fine of 25,500 pesos to be paid within three months from notice, and dismissed the charge of gross misconduct as a member of the Philippine Bar.

Remember This

The line worth memorizing is that without corruption, clear intent to violate the law, or flagrant disregard of an established rule, a judge's delayed release of decision hard copies is simple misconduct, not gross misconduct. Examiners like to use this case to test the distinction between simple and gross misconduct, the mitigating circumstances under the 2025 Code of Judicial Conduct and Accountability, and the requirement that certificates of service reflect the true docket.