The Supreme Court found Hon. Juliet C. Azarraga-Chanyongco, Presiding Judge of Branch 49, Regional Trial Court (RTC), Manila, in her capacity as former Presiding Judge of Branch 53, Metropolitan Trial Court (MTC), Caloocan City, liable for gross ignorance of the law and procedural rules, and for gross neglect of duty. She was fined PHP 200,000.00 and suspended from office without salary and other benefits for a period of one year and one day.
The Case
Under a Memorandum dated October 25, 2022, the Office of the Court Administrator (OCA) charged Judge Azarraga-Chanyongco with gross misconduct constituting violations of the Code of Judicial Conduct, gross ignorance of the law, and gross inefficiency, based on the results of a judicial audit conducted in Branch 53, MTC, Caloocan City.
The judicial audit was conducted on May 23 to 25, 2022, May 30 to 31, 2022, and June 1, 2022, in connection with the promotion of Judge Azarraga-Chanyongco from Branch 53, MTC, Caloocan City to Branch 49, RTC, Manila, and to verify information received by the OCA regarding alleged irregularities and inefficiency.
The audit found that Judge Azarraga-Chanyongco committed delays in the arraignment of several accused. The hearing of 359 arraignments were reset several times, but eventually never pushed through. Using six sample cases, the audit team found the reasons for postponement included the COVID-19 pandemic, absence of the judge, absence of the public prosecutor, absence of one or both of the parties, and lack of material time. The intervals between settings spanned from one to three months.
The audit also found that she motu proprio routinely set cases for clarificatory hearing to delay the resolution of her cases. One example was the ex-parte proceeding in Civil Case No. 15-31097, titled Sps. Adela & Esteban Molina v. Sps. Armin & Noemi Rodriguez, for recovery of possession with damages, which was already ripe for decision after the court admitted the formal offer of evidence in its Order dated June 30, 2018. In Criminal Case No. 265853, titled People v. Simon for direct assault, the case was set for clarificatory hearing even though it only had a pending motion for partial reconsideration.
She was also found to have caused delay by setting even a mere formal offer of evidence for hearing, as in Criminal Case No. 263172, titled People v. Santos for estafa. She was likewise found guilty of delay by archiving cases instead of proceeding with the trial in absentia, having erroneously ordered the archiving of 14 cases even though the respective accused had already been arraigned.
Acting Presiding Judge Concepcion Billones reported that several accused who had pleaded guilty were not released despite their completed service of sentence.
The Issue
Whether Judge Azarraga-Chanyongco should be held administratively liable for gross ignorance of the law and procedural rules and for gross neglect of duty in the performance of official functions.
The Ruling
The Court found Judge Azarraga-Chanyongco liable and resolved the complaint as follows: she was found LIABLE for gross ignorance of the law and procedural rules and FINED PHP 200,000.00, payable within three months from receipt of the Decision; she was found LIABLE for gross neglect of duty in the performance of official functions and SUSPENDED from office without salary and other benefits for a period of one year and one day effective immediately; and she was STERNLY WARNED that a repetition of the same or similar infractions shall be dealt with more severely by the Court.
The Court also amended Section 3(e), Rule 2 of the Internal Rules of the Supreme Court (A.M. No. 10-4-20-SC) to increase the threshold of penalties in administrative cases involving judges, officials, or personnel of the Judiciary cognizable by the Court En Banc.
By the Numbers
- 359 arraignments reset but never pushed through
- 14 cases erroneously archived despite the accused having been arraigned
- PHP 200,000.00 fine for gross ignorance of the law and procedural rules
- One year and one day suspension for gross neglect of duty
- Audit conducted May 23–25, May 30–31, and June 1, 2022
- OCA Memorandum dated October 25, 2022
- Internal Rules fine threshold raised from PHP 40,000.00 to PHP 200,000.00; suspension threshold raised from one year to three years
The Court's Reasoning
The Court noted that Judge Azarraga-Chanyongco violated the period for arraignment prescribed under Section 1(g), Rule 116 of the Rules of Court, and showed an abject lack of ability to manage her cases. There were hearing days where the accused may have been present and could have already been arraigned, but the hearings were postponed for various other reasons. Arrangements could have been made for the arraignment to be called first in the calendar and special counsels appointed in place of absent prosecutors or Public Attorney's Office (PAO) lawyers so that the arraignment could proceed.
On the clarificatory hearings, the Court observed that cases should have long been disposed of had the judge simply resolved them based on the evidence presented, noting that it is not for the judge to actively elicit evidence from any party during a clarificatory hearing.
In imposing penalties, the Court cited Office of the Court Administrator v. Cabrera-Falle and Office of the Court Administrator v. Balo, where it had seen fit to impose the penalty of fine in past similar cases where a respondent judge is charged with more than one serious offense, such as gross neglect of duty and gross ignorance of the law.
The Court further explained that the amendment of the Internal Rules to increase penalty thresholds would allow more administrative cases to be processed through streamlined procedures, reducing the burden on the Court En Banc's dockets and promoting judicial economy.
Source: Office of the Court Administrator v. Hon. Juliet C. Azarraga-Chanyongco, A.M. No. RTJ-26-118 (Formerly JIB FPI No. 22-214-RTC), promulgated June 3, 2026, penned by Associate Justice Lazaro-Javier.
This report summarizes a public Supreme Court decision and is not legal advice.