While the evidence presented was insufficient to establish prohibited partisan political activity (electioneering) or grave misconduct/oppression under the high standard of proof required in administrative cases against judges, a judge's conduct must nonetheless be free from the appearance of impropriety, and actions that could be misinterpreted as partisan, even if well-intentioned (like explaining election mechanics at a political rally), warrant admonishment under the Canons of Judicial Ethics.

The case arose in the context of intense local political rivalry in Dauin, Negros Oriental, following the April 7, 1978 elections. Respondent Judge Araula's wife was the incumbent Mayor and KBL Chairman in Dauin, while the complainant and his witnesses were associated with the opposing Pusyon Bisaya party. The charges stemmed from incidents occurring shortly before and after these elections, reflecting the bitter political division and personal animosity between the factions, particularly involving the Judge's family and Atty. Rudy Enriquez, a relative and political opponent.

• Complainant Lamberto Macias, relying on witness accounts, accused Respondent Judge Gibson Araula of electioneering by delivering partisan speeches supporting KBL candidates at political rallies on March 20 and April 2, 1978, in Barangays Casile and Maayongtubig, Dauin, Negros Oriental.
• It was alleged that on April 9, 1978, two days after the KBL candidates lost in Dauin, the enraged Judge, accompanied by family and alleged "goons," went to the public market, threatened, coerced, and ejected market vendors identified as Pusyon Bisaya followers, overturning tables and equipment.
• It was further alleged that on the same evening (April 9, 1978), Judge Araula, appearing drunk, along with his sons and "goons," confronted and challenged Atty. Rudy Enriquez and his brother Douglas Enriquez (Pusyon coordinators) to a fistfight, during which the Judge's son, Ramon Araula, allegedly tore Douglas' collar, slapped him, and threw a lighted cigarette at Atty. Rudy Enriquez' face.
• Witnesses for the complainant included Claro T. Macias and Teofilo Versano (testifying on the March 20 rally speech), Primitivo Aletcha (testifying on the April 2 rally speech), Felix Soler and Sabina Bongalando (testifying on the market incident), and Atty. Rudy Enriquez and Douglas Enriquez (testifying on the confrontation).
• Respondent Judge Araula denied delivering partisan speeches, claiming he only explained the mechanics of the election and block voting upon request at the rallies.
• Respondent Judge Araula denied ejecting or threatening vendors, stating he had no authority to do so, and denied overturning tables or being accompanied by "goons" (identifying companions as family, a policeman, and an AFP Major).
• Respondent Judge Araula admitted going to the market on April 9, 1978, after being informed that Pusyon followers were inciting people against his wife (the Mayor), intending to verify the report and confront those involved.
• Respondent Judge Araula admitted confronting Atty. Rudy Enriquez angrily after provocation but denied challenging him to a fight or being drunk; he admitted his son Ramon was involved in an altercation but claimed it was the son's individual act which he tried to stop.
• Complainant Lamberto Macias was identified as a nominal complainant, not an eyewitness to the

• Respondent Judge engaged in serious infractions of the law through illegal and unethical participation in partisan politics and electioneering by delivering campaign speeches for KBL candidates.
• Respondent Judge committed serious infractions of the law, oppression, and grave misconduct by threatening, coercing, and physically ejecting market vendors who supported the opposition party (Pusyon Bisaya) after his party's candidates lost.
• Respondent Judge, while drunk, together with his sons and "goons," provoked a confrontation and challenged opposition coordinators to a fistfight.

• Respondent Judge denied delivering partisan political speeches, stating he merely explained election mechanics (block voting, regional representation) upon request, which is not prohibited electioneering.
• Respondent Judge denied ejecting vendors or overturning market equipment, asserting he lacked the authority for such actions and that police verification showed vendors were selling normally the next day.
• Respondent Judge denied being drunk during the April 9 incident and refuted the claim he challenged anyone to a fight, although admitting he confronted Atty. Enriquez angrily due to reports of insults against his wife.
• Respondent Judge argued that the complainant's witnesses were biased due to political affiliation and personal animosity stemming from long-standing political and familial conflicts.
• Respondent Judge contended that the actions of his son during the confrontation were individual acts for which the Judge should not be held liable, especially as he tried to de-escalate the situation.

• Whether respondent Judge Araula engaged in illegal partisan politics and electioneering by delivering speeches at KBL rallies on March 20 and April 2, 1978.
• Whether respondent Judge Araula committed oppression and grave misconduct by his actions in the Dauin public market and his confrontation with the Enriquez brothers on April 9, 1978.
• Whether the evidence presented met the standard of proof required to hold the respondent Judge administratively liable for the charges.

• The Court adopted the findings and recommendations of the Investigating Justice, concluding that the complainant failed to substantiate the charges of electioneering (Charges I-A and I-B) and oppression/grave misconduct related to the market incident (Charge II-A) with the required degree of proof, which in administrative cases involving judges approaches proof beyond reasonable doubt.
• The testimonies regarding electioneering were found to be in equilibrium, tainted by political bias on both sides, and insufficient to overcome the respondent's defense that he merely explained election mechanics.
• The evidence regarding the market incident (ejecting vendors, overturning tables) was deemed unreliable, hearsay, or contradicted by witness testimony and police reports; the testimony of Sabina Bongalando was found inconsistent and unreliable.
• Regarding the confrontation (Charge II-B), the Court accepted the Investigator's finding that the Judge did angrily confront Atty. Rudy Enriquez ("You are brave, you challenge me!") in reaction to perceived insults against his wife, which was deemed a natural human reaction but unbecoming of a judge.
• The Court found no concrete evidence that the Judge was drunk and held that the actions of the Judge's son were individual acts for which the Judge was not responsible.
• Despite exonerating the Judge on the specific charges due to insufficient proof, the Court held that his presence and actions at the political rallies (explaining election mechanics on the rally platform) and his angry confrontation in the market created an appearance of impropriety, falling short of the standard prescribed by the Canons of Judicial Ethics.
• Judge Gibson A. Araula was reprimanded with a stern admonition that a repetition of similar acts would be dealt with more severely.

• Standard of Proof in Administrative Cases Against Judges: The Court cited Suerte vs. Ugbinar (quoting In re Horrilleno), stating that administrative proceedings against judges are 'highly penal in nature' and the charge 'must, therefore, be proved beyond reasonable doubt' or at least by a 'preponderance of the evidence, much less beyond a reasonable doubt'. In this case, the Court found the evidence presented by the complainant did not meet this exacting standard for Charges I-A, I-B, and II-A.
• Preponderance of Evidence (Rule 133, Sec. 1, New Rules of Court): Defined generally as the greater weight of credible evidence. The Investigating Justice explicitly referenced this rule, noting that while numerical superiority of witnesses isn't determinative, it can be considered alongside other factors like witness interest and testimony probability when evidence conflicts. It was used to weigh the conflicting testimonies regarding the alleged electioneering, ultimately favoring the respondent's version due to perceived bias and improbability in the complainant's evidence.
• Appearance of Impropriety (Canon 3, Canons of Judicial Ethics): This principle dictates that a judge's official conduct and personal behavior should be free even from the appearance of impropriety and must be beyond reproach. The Court applied this doctrine to reprimand the Judge, finding that even if his explanation of election mechanics at political rallies was well-intentioned and his confrontation understandable as a human reaction, these actions created a perception of partisanship and lack of temperance, thus violating the canon.
• Judicial Temperament (Canon 4, Canons of Judicial Ethics): This principle requires judges to be temperate and patient. The Court invoked this implicitly by advising the Judge to be "more temperate and patient, more forbearing and more forgiving" and noting that he should have avoided the confrontation, implying his angry reaction, while understandable, fell short of the expected judicial conduct.

• "x x x This is to defer the basic concept first announced in 1922 in this, jurisdiction in Justice Malcolm's opinion in the leading case of In re Horrilleno that proceedings of this character being 'in their nature highly penal,' the charge 'must, therefore, be proved beyond reasonable doubt.' (43 Phil. 212). To paraphrase the opinion further, there is no showing of the alleged incompetence and gross ignorance of the law 'by a preponderance of the evidence, much less beyond a reasonable doubt'. Such an exacting standard has been adhered to by this Court in subsequent decisions." (Quoting Suerte vs. Ugbinar)
• "Members of the bench should refrain from any conduct that should in any way give rise to a suspicion, whether founded or not." (Citing Azupardo vs. Buenviaje)
• "The personal and official actuations of every member of the Bench should be beyond reproach and above suspicion." (Citing Dy Taban Hardware Auto Supply Co. vs. Tapucar)
• "3. Avoidance of appearance of impropriety - A Judge's official conduct should be free from the appearance of impropriety, and his personal behavior, not only in the bench and in the performance of judicial duties, but also in his everyday life, should be beyond reproach." (Quoting Canon 3, Canons of Judicial Ethics)
• "4. Essential conduct, - He should be temperate, x x x, patient x x x" (Quoting Canon 4, Canons of Judicial Ethics)
• "Judges, indeed, should be not only men of highest integrity but they should also at all times conduct themselves in such a manner as to be above suspicion." (Citing Li vs. Mijares, etc.)

• Suerte vs. Ugbinar (75 SCRA 69): Cited for establishing the high standard of proof (akin to beyond reasonable doubt) required in administrative cases against judges, following In re Horrilleno.
• In re Horrilleno (43 Phil. 212): Cited (via Suerte) as the leading case establishing that administrative proceedings against judges are highly penal in nature requiring proof beyond reasonable doubt.
• Enriquez vs. Araula (54 SCRA 232): Referenced within the Suerte citation as a subsequent decision adhering to the Horrilleno standard; likely also contextually relevant as it involves the same respondent judge and possibly related complainants/political adversaries.
• Tombo vs. Medina (55 SCRA 13): Cited within the Suerte citation as adhering to the Horrilleno standard.
• Lampauog vs. Villarojo (55 SCRA 304): Cited within the Suerte citation as adhering to the Horrilleno standard.
• Bartolome vs. de Borja (71 SCRA 153): Cited within the Suerte citation as adhering to the Horrilleno standard.
• Tolentino vs. Tiong (Adm. Case No. 535-MJ, Aug 21, 1976): Cited within the Suerte citation as adhering to the Horrilleno standard.
• Amosco vs. Magro (Adm. Case No. 439-MJ, Sept. 30, 1976): Cited within the Suerte citation as adhering to the Horrilleno standard.
• Caballo vs. Celis (83 SCRA 620): Cited as reiterating the basic concept (high standard of proof) from Horrilleno.
• Lopez vs. Fernandez (99 SCRA 603): Cited as reiterating the basic concept (high standard of proof) from Horrilleno.
• V.S. vs. Caro (32 Phil. 413): Cited regarding the factors (number of witnesses, probability, interest) courts may consider in determining the preponderance of evidence.
• People vs. Esquilona (58 Phil. 295): Cited for the principle that while the number of witnesses isn't determinative, the numerical factor may be given weight in cases of conflicting testimony, assuming witnesses are otherwise equally credible.
• Azupardo vs. Buenviaje (82 SCRA 369): Cited for the principle that judges should refrain from conduct giving rise to suspicion, whether founded or not.
• Dy Taban Hardware Auto Supply Co. vs. Tapucar (102 SCRA 495): Cited for the principle that personal and official actuations of judges should be beyond reproach and above suspicion.
• Li vs. Mijares (65 SCRA 167): Cited for the general principle that judges must conduct themselves to be above suspicion.
• Castillo vs. Barsana (63 SCRA 388): Cited for the general principle that judges must conduct themselves to be above suspicion.
• Jugueta vs. Boncaros (60 SCRA 27): Cited for the general principle that judges must conduct themselves to be above suspicion.
• Lugue vs. Kayanan (29 SCRA 165): Cited for the general principle that judges must conduct themselves to be above suspicion.

• P.D. No. 1296, Section 34: Cited for the legal definition of "election campaign" or "partisan political activity," specifically subsections (2) and (3) regarding holding rallies and making speeches for or against candidates. The 'Provided' clause, excluding simple expressions of opinion or mentioning names of supported candidates, was also noted.
• Rules of Court, Rule 133, Section 1: Cited regarding the principle of "preponderance of evidence" and the factors courts consider in weighing evidence.
• Canons of Judicial Ethics, Canon 3 (Avoidance of appearance of impropriety): Cited as the basis for reprimanding the Judge, emphasizing that conduct must be free from even the appearance of impropriety.
• Canons of Judicial Ethics, Canon 4 (Essential conduct - temperance, patience): Cited in relation to the Judge's angry confrontation, highlighting the expected judicial demeanor.