In Heinz R. Heck v. Judge Anthony E. Santos, the Supreme Court addressed the issue of a judge’s accountability when delegating the drafting of a court decision to one party’s counsel and subsequently adopting it verbatim. The Court ruled that this practice violates the Code of Judicial Conduct, specifically Canon 2 (avoiding impropriety) and Canon 3 (performing duties honestly, impartially, and diligently). This case reinforces the principle that judges must personally and directly prepare judgments, ensuring fairness, impartiality, and public trust in the judicial process, highlighting the importance of judges upholding their ethical obligations to preserve the integrity of the legal system.

“Ghostwritten” Judgments: Did Judge Santos Abandon His Duty of Impartiality?

The administrative case against Judge Anthony E. Santos arose from Civil Case No. 94-334, where Heinz R. Heck was a defendant. After his counsel withdrew, Heck and his co-defendants did not receive notice of a crucial hearing, leading the court to consider their right to present evidence as waived. The twist? Judge Santos then authorized the plaintiff’s counsel to draft the decision, and, remarkably, adopted the draft verbatim. Heck filed an administrative complaint alleging violations of the Revised Rules of Court, the Code of Judicial Ethics, gross ignorance of the law, and violation of the 1987 Constitution.

Judge Santos defended his actions by stating that he diligently reviewed the draft decision and that ordering the plaintiff’s counsel to prepare it was consistent with his practice of promptly disposing of cases. However, the Office of the Court Administrator (OCA) found that while the other allegations lacked merit, the verbatim adoption of the counsel-drafted decision was indeed irregular. The Supreme Court agreed with the OCA’s findings. The Court emphasized the critical importance of judges using their own discernment and analysis in every case. Judges should be independent thinkers and should use their learned discretion when analyzing evidence presented before them.

Building on this principle, the Supreme Court underscored that delegating the core judicial function of preparing a judgment compromises the integrity of the entire legal process. The Court referred to Canon 2, which states that a judge should avoid impropriety and the appearance of impropriety in all activities. In line with that, Canon 3 says a judge should perform official duties honestly, and with impartiality and diligence in adjudicative responsibilities. Such actions erodes public trust in the judiciary and creates an impression of bias or favoritism. The duty to deliver fair judgments falls squarely on the shoulders of judges, who must personally craft these judgments based on their understanding and analysis of the evidence and the applicable law. This personal touch is a hallmark of judicial responsibility, designed to prevent any semblance of injustice or bias.

Moreover, the Supreme Court highlighted the importance of maintaining judicial independence and integrity in the decision-making process. Allowing a party’s counsel to draft a decision and adopting it verbatim not only violates the explicit provisions of the Revised Rules of Court but also undermines the impartiality expected of judges. Section 1 of Rule 36 explicitly mandates that a judgment or final order determining the merits of a case shall be in writing, personally and directly prepared by the judge. The court further said it must be personally signed by him.

SECTION 1. Rendition of judgments and final orders. — A judgment or final order determining the merits of the case shall be in writing, personally and directly prepared by the judge, stating clearly the facts and the law on which it is based, signed by him, and filed with the clerk of court.

By delegating this responsibility, Judge Santos essentially abdicated his duty. Furthermore, it gave rise to the perception of partiality and undue influence.

As such, even in the absence of malicious intent, the Supreme Court emphasized the crucial role that impartiality plays in every judgement, because every action that a judge takes inside the courtroom should always avoid the appearance of being unfair, biased and unjust. A judge’s conduct must be beyond reproach. Lack of malice or bad faith does not excuse such a blatant disregard of judicial duties.

Given that the violations of the Code of Judicial Conduct qualify as a serious offense, the Supreme Court imposed a fine of P20,000.00 to be deducted from Judge Santos’ retirement benefits, differing from the OCA’s recommended fine of P5,000.00. The original recommendation was inconsistent with the gravity of the violation. In addition to the fine, the Court directed the Integrated Bar of the Philippines to investigate the complainant’s request for disbarment.

FAQs

What was the key issue in this case?	The central issue was whether Judge Santos violated the Code of Judicial Conduct by delegating the drafting of a decision to the plaintiff’s counsel and then adopting the draft verbatim. The Supreme Court found this practice unacceptable.
Why did the Court consider this a serious violation?	The Court deemed it serious because it violated the judge’s duty to personally and directly prepare judgments, thereby compromising impartiality and undermining public trust in the judicial process. This also goes against the Constitution.
What specific Canons of the Code of Judicial Conduct were violated?	Judge Santos violated Canon 2, which requires judges to avoid impropriety and the appearance of impropriety, and Canon 3, which mandates that judges perform their duties honestly, impartially, and diligently.
What was the punishment imposed on Judge Santos?	The Supreme Court fined Judge Santos P20,000.00, to be deducted from his retirement benefits. This was a greater fine than initially recommended.
What was the basis for the administrative complaint against Judge Santos?	The complaint alleged violations of the Revised Rules of Court, the Code of Judicial Ethics, gross ignorance of the law, and a violation of the 1987 Constitution, stemming from the manner in which he handled Civil Case No. 94-334.
What was Judge Santos’ defense in this case?	Judge Santos argued that he thoroughly reviewed the draft decision and believed that ordering the plaintiff’s counsel to prepare the draft aligned with his practice of promptly resolving cases.
What action was taken regarding the complainant’s request for disbarment?	The Supreme Court referred the disbarment request to the Integrated Bar of the Philippines (IBP) for further investigation, report, and recommendation.
Is a judge’s lack of bad faith a valid defense in such cases?	No, the Court emphasized that a lack of malice or bad faith does not excuse the violation of judicial duties and the compromising of judicial integrity and impartiality.

In conclusion, the Heinz R. Heck v. Judge Anthony E. Santos case underscores the critical role of judicial accountability in maintaining public trust and ensuring the integrity of the legal system. The Supreme Court’s ruling emphasizes the fundamental duty of judges to personally and directly prepare judgments, avoiding any appearance of impropriety and upholding the impartiality expected of them. This decision reinforces that a judge’s actions are subject to review and sanction to ensure compliance with ethical obligations.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

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: HEINZ R. HECK v. JUDGE ANTHONY E. SANTOS, A.M. No. RTJ-01-1630, April 09, 2003