Upholding Judicial Integrity: The Consequences of Disobeying Court Orders
In Gaspar v. Judge Adaoag, the Supreme Court fined a judge P10,000 for deciding a case while suspended, stressing that its orders must be obeyed fully.
A resolution of the Supreme Court suspending a judge is not a suggestion, and it cannot be obeyed partially or only when convenient. In Gaspar v. Judge Luisito T. Adaoag (A.M. No. MTJ-04-1565, August 16, 2006), the Court penalized a municipal circuit trial court judge who issued a ruling in a pending election case while under an indefinite suspension it had ordered.
What happened
Rolando Gaspar was the elected and proclaimed chairman of Barangay Pance, Ramos, Tarlac in the 15 July 2002 elections. Anastacio Bonifacio filed an election protest against him before the Municipal Circuit Trial Court of Gerona-Ramos-Pura, Tarlac, presided over by Judge Adaoag. The case was docketed as Election Case No. 02-07.
While that protest was pending, the Court's First Division suspended Judge Adaoag in a Resolution dated 4 August 2003, pending the final outcome of criminal proceedings against him or until further orders from the Court.
On 25 November 2003 — while still under suspension — Judge Adaoag rendered a decision in the election case declaring Bonifacio the duly elected Punong Barangay and ordering Gaspar to vacate the position and turn it over peacefully. Gaspar then filed an administrative complaint, alleging a violation of Section 3(e) of Republic Act No. 3019 and Canon 2 of the Code of Judicial Conduct.
The judge's defense
Judge Adaoag claimed good faith. He argued that the Court's use of the word "or" in the suspension resolution gave him two alternatives: that his suspension ended when
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