CASTRO, OLY BIEN
JD1-A
BULACAN STATE UNIVERSITY- COLLEGE OF LAW
CASE DIGEST
Office of the Court Administrator vs. Judge Florentino V. Floro Jr.
(A.M. No.RTJ-99-1460, A.M. No. 99-7-273, and A.M. No. RTJ-06-1988)
FACTS:
- Judge Florentino V. Floro (respondent) was appointed Regional Trial Court
(RTC) Judge of Branch 73 in Malabon City and as by personal request, an audit
was conducted on March 2 and 3, 1999. In this first case (A.M. No. RTJ-99-
1460), as the report was passed by the audit team, Court Administrator, Alfredo
L. Benipayo moved that his report be considered as an administrative complaint
on 13 different charges against Judge Floro and forced to undergo appropriate
psychological or mental examination.
- In progress, the consultant of the Office of the Court Administrator, Justice Pedro
Ramirez, the Court placed Floro under preventive suspension for the “duration of
the investigation on the charges against him”, as Floro moved to inhibit or
disqualify Ramirez as investigator, but the Court ruled against it. In continuation,
after the release of the “Partial Report” conducted by Justice Ramirez, he
recommended that Judge Floro be dismissed from office "by reason of insanity
which renders him incapable and unfit to perform the duties and functions of a
judge of the RTC. In line with this, Judge Floro filed seven cases for those he
perceived to have connived to remove and/or suspend him from office.
- In the second case (A.M. No. 99-7-273) and third case (A.M. No. RTJ-06-1988),
it was likewise to the subject matter in charge of the aforementioned case as
mentioned regarding the utilization on his advantage of his moral ascendency to
settle and dismiss a frustrated homicide case without the presence of the trial
prosecutor and Judge Floro’s decisions and demeanor as a judge in violation of
the Code of Judicial Conduct.
- Upon the discussion of the Office of the Court Administrator (OCA) on each of
the 13 charges, 7 of which constitute with a corresponding penalty which may
only be inextricably linked and will act as a common thread is the charge of
mental illness on Judge Floro.
- Upon many psychiatric evaluations, reports state of an evidence of a developing
psychotic process and prominent ego disintegration, focused more on the
ideations of what Judge Floro can do and can see, frankly diagnosed with mild
mental retardation which is below the cognitive efficiency of a judge, thus,
hampering his primary role in dispensing justice, and the misconstruing signals
from his environments as to what he ideates or percepts, tainting his
occupational and social functioning thus declaring or rendering him unfit to
discharge his duties as a judge as ultimately recommended and reported by
Justice Ramirez of the OCA in correlation of the various findings, tests, and
examinations. He is recommended to be removed and dismissed from his office
as judge due to “insanity” as medically referred to, as psychosis.
- The Supreme Court (SC) resolved that Judge Florentino V. Floro Jr. was relieved
of his duties as judge of the RTC, considering him to be separated from the
service due to a medically disabling condition of the mind, and the court
dismissed two of the cases charged against him, (A.M. No.RTJ-99-1460) for
being moot and academic, and (A.M. No. RTJ-06-1988) for lack of merit.
ISSUE/S:
- Whether or not Judge Floro is unfit to become a judge and discharge the duties
of administering justice.
- Whether psychiatric evaluations and findings of the Supreme Court Clinic are
permissible or valid.
- Whether or not the investigation on the charges against Judge Floro were
deemed in violation of his right to due process as to the court’s disregarding of
the testimonies of his witness and the dismissal of his motions for
reconsideration.
RULING:
- Yes. The Supreme Court ruled that Judge Floro is unfit of becoming a judge and
is unable to administer justice due to his mental condition or disability.
- Yes. Upon the findings of the mental health professionals of the SC Clinic and
even private practitioners, proved the admissibility that Judge Floro unfit to
perform duties and functions as a judge.
- No. Upon cross examination of his own witnesses, it is conjunctive to what the
SC Clinic experts have evaluated on his doubtful capacity due to insanity, and
clarified his unfitness to remain in office as a judge. The motions for
reconsideration were denied due to Judge Floro’s indication of the latter’s
intention to disregard and disobey the legal orders of the Court as he moved to
inhibit and filed cases to revoke licenses of health experts of the SC Clinic.
ANALYSIS:
- The decision of the SC is inclined with the numerous psychiatric evaluations and
psychological tests which indicate Judge Floro’s mental unsuitability. It is proven
by both SC Clinic mental physicians and Judge Floro’s own doctors.
- Judges adhere to the concept of judicial detachment and thus operate in the
accepted and limited notions of justice. as expected by them withholding judicial
power. Judge Floro’s mental incapability is inclined with superfluous notions that
influences him in making decisions as he lacks judicial temperament of
competence and objectivity.
- The consideration of Judge Floro’s witnesses and their testimonies did not take
precedence over the findings of mental unfitness.
- This administrative case denotes that gross ignorance of law may remove public
confidence in the judiciary as based on the audit review and the violation of the
proper judicial conduct of an authority vested with judicial power such as a judge.
CONCLUSION:
- Hence, the Supreme Court upheld the decision to remove or dismiss Judge Floro
from office as judge of RTC due to his mental unfitness.
