Case Digest: ATTY. MELVIN D.C. MANE v. JUDGE MEDEL ARNALDO B. BELEN

ATTY. MELVIN D.C. MANE v. JUDGE MEDEL ARNALDO B. BELEN

A.M. No. RTJ-08-2119, 30 June 2008

An alumnus of a particular law school has no monopoly of knowledge of the law.

Petitioner Atty. Melvin D.C. Mane filed a letter-complaint to the Office of the Court Administrator (OCA) charging respondent Judge Medel Arnaldo B. Belen of ―demeaning, humilating, and berating‖ him during a hearing of Rural Bank of Cabuyao, Inc. v. Samue Malabanan, et al. where Mane was counsel for the plaintiff. During the proceedings, Belen asked Mane about the latter’s law school. When Mane answered that he came from Manuel L. Quezon University (MLQU), Belen told him: ―Then you’re not from UP. Then you cannot equate yourself to me because there is a saying and I know this, not all law students are created equal, not all law schools are created equal, not all lawyers are created equal despite what the Supreme Being that we all are created equal in His form and substance.‖

Belen further lambasted Mane and lectured him on the latter’s person, seemingly disregarding the case at hand. Subsequently, the OCA, upon evaluation, found that Belen’s insulting remarks were unwarranted and inexcusable and recommended a reprimand of Belen.

ISSUE:

Whether or not the statements and actions made by Judge Belen during the hearing constitute conduct unbecoming of a judge and a violation of the Code of Judicial Conduct

HELD:

The Court held that an alumnus of a particular law school has no monopoly of knowledge of the law. By hurdling the Bar Examinations which the Court administers, taking of the Lawyer’s oath, and signing of the Roll of Attorneys, a lawyer is presumed to be competent to discharge his functions and duties as, inter alia an officer of the court, irrespective of where he obtained his law degree. For a judge to determine the fitness or competence of a lawyer primarily on his alma mater is clearly an engagement in an argumentum ad hominem.

A judge must address the merits of the case and not the person of the counsel. If Judge Belen felt that his integrity and dignity were being ―assaulted,‖ he acted properly when he directed complainant to explain why he should not be cited for contempt. He went out of bounds, however, when he engaged on a supercilious legal and personal discourse.

The Court reminded members of the bench that even on the face of boorish behavior from those they deal with, they ought to conduct themselves in a manner befitting gentlemen and high officers of the court.