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Updated 21st February 2025
Office of the Court Administrator vs. Floro, Jr.
A landmark administrative case involving a Regional Trial Court judge who was ultimately relieved of his functions due to a medically disabling condition of the mind, while being awarded back wages on equitable grounds despite his role in delaying case resolution.

Primary Holding

The Supreme Court ruled to relieve Judge Florentino V. Floro, Jr. of his functions as Judge of RTC Branch 73, Malabon City due to a medically disabling condition of the mind that rendered him unfit to discharge judicial functions, while awarding him back wages for 3 years on equitable grounds.

Background

The case centers on Judge Florentino V. Floro Jr.'s fitness to serve as a judge of the Regional Trial Court. After withdrawing his first application in 1995 due to concerning psychological evaluations, he reapplied in 1998 and was appointed despite similar psychological concerns, mainly due to his impressive academic background. Upon his own request for an audit in March 1999, various issues about his conduct came to light, leading to his preventive suspension by July 1999, merely eight months into his position. The Office of the Court Administrator filed administrative charges against him, encompassing 13 different allegations ranging from procedural violations to fundamental concerns about his mental fitness, particularly given his proclaimed beliefs in psychic powers, dwarf friends, and unusual practices like wearing colored robes in court. The case became a landmark decision addressing the intersection of mental fitness, judicial temperament, and the limits of personal beliefs in judicial service.

History

  • 1995: First applied for judgeship but withdrew after psychological evaluation revealed "ego disintegration"

  • June 1998: Applied again, psychological evaluation showed problems but got appointed due to academic background

  • November 4, 1998: Appointed as RTC Judge of Branch 73, Malabon City

  • March 2-3, 1999: Audit conducted on his sala upon his request

  • July 20, 1999: Placed under preventive suspension

  • March 31, 2006: Final decision rendered

Facts

  • 1. Judge Floro first applied for judgeship in 1995 but withdrew after psychological evaluation showed "ego disintegration" and "developing psychotic process"
  • 2. In 1998, he reapplied and the required psychological evaluation exposed problems with self-esteem, mood swings, confusion, social deficits, and paranoid ideations
  • 3. The Judicial and Bar Council allowed him to seek second opinion from private practitioners, which was favorable
  • 4. He was appointed as RTC Judge of Branch 73, Malabon City on November 4, 1998
  • 5. He circulated calling cards featuring his academic achievements and bar exam ranking
  • 6. He allowed announcements of his qualifications during court sessions
  • 7. He permitted his chambers to be used as sleeping quarters for his aide
  • 8. He rendered judicial resolutions without written orders
  • 9. He openly declared being "pro-accused" in criminal cases
  • 10. He engaged in activities resembling law practice while serving as judge
  • 11. He referenced psychic phenomena in official court decisions
  • 12. He professed having three "dwarf friends" named Luis, Armand and Angel
  • 13. He wore blue robes during court sessions and changed to black attire on Fridays
  • 14. He conducted healing sessions in his chambers during break time

Arguments of the Petitioners

  • 1. Judge Floro was mentally and psychologically unfit to serve as a judge
  • 2. He violated multiple provisions of the Code of Judicial Conduct
  • 3. His actions and beliefs compromised the integrity of the judiciary
  • 4. He should be dismissed from service

Arguments of the Respondents

  • 1. His academic excellence qualified him for the position
  • 2. His beliefs did not affect his judicial functions
  • 3. The psychological evaluations were incomplete or inaccurate
  • 4. Private practitioners gave him favorable evaluations
  • 5. His actions were within acceptable judicial conduct

Issues

  • 1. Whether Judge Floro is mentally/psychologically fit to continue as RTC Judge
  • 2. Whether his actions constitute violations of judicial conduct
  • 3. Whether he is entitled to back wages despite his role in case delays

Ruling

  • 1. Judge Floro must be relieved of his functions due to mental/psychological disability
  • 2. Imposed P40,000 fine for seven violations of judicial conduct
  • 3. Awarded back wages for 3 years on equitable grounds
  • 4. His separation is not a penalty but a necessity due to disability
  • 5. He is not disqualified from other government positions that don't require dispensing justice

Doctrines

  • 1. Equity does not demand blameless suitors - even those at fault may seek equitable relief
  • 2. Judicial objectivity requirement - judges must maintain impartiality and avoid personal beliefs affecting decisions
  • 3. Judicial temperament doctrine - judges must exhibit proper judicial behavior and demeanor

Precedents Cited

  • 1. Ulep v. Legal Clinic, Inc. - On proper content of professional cards
  • 2. Poso v. Judge Mijares - On requirements for probation cases
  • 3. State Prosecutors v. Muro - On required judicial objectivity
  • 4. Gloria v. Court of Appeals - On preventive suspension periods

Statutory and Constitutional Provisions

  • 1. Code of Judicial Conduct, Canon 2, Rule 2.02
  • 2. Rules of Court, Rule 140 (as amended)
  • 3. Presidential Decree No. 968 (Probation Law)
  • 4. Administrative Circular No. 1
  • 5. Republic Act No. 4200 (Anti-Wiretapping Law)