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PANGILINAN V. CONTRERAS [ A.M. No. RTJ-25-092, April 07, 2025 ]

PANGILINAN V. CONTRERAS [ A.M. No. RTJ-25-092, April 07, 2025 ]
Posted by:PJP
Interactive Case Summary: Pangilinan v. Contreras

SUPREME COURT - THIRD DIVISION

[ A.M. No. RTJ-25-092, April 07, 2025 ]

EDRALYN PANGILINAN, COMPLAINANT, VS. HON. LELU P. CONTRERAS, RESPONDENT.

Case Summary: Judicial Conduct & Misconduct

  • This administrative case examines the conduct of Judge Lelu P. Contreras following the discovery of a large-scale "shabu" laboratory. A complaint accused her of delaying a search warrant and other misconduct. While the Supreme Court cleared her of deliberately delaying the warrant, it found her guilty of two counts of Simple Misconduct for her improper behavior during a subsequent congressional hearing and for holding an unauthorized press conference, fining her a total of PHP 100,000.00.
  • The Discovery: Police suspected a warehouse in Virac, Catanduanes was a clandestine shabu laboratory. They consulted Judge Contreras about applying for a search warrant on November 25, 2016, but lacked sufficient evidence.
  • The Inspection: On November 26, 2016, police, along with the town mayor and the property owner, inspected the warehouse (without a warrant) and confirmed it was a drug lab.
  • Warrant Issuance: Police formally applied for a search warrant at 3:00 p.m. that day. After conducting searching questions, Judge Contreras issued the warrant at 5:50 p.m.
  • Public Backlash: The incident led to a public hearing by the House Committee on Dangerous Drugs, where Judge Contreras's actions were questioned. This prompted a complaint against her.
  • Administrative Complaint: Edralyn Pangilinan filed a complaint against Judge Contreras for Gross Ignorance of the Law, Gross Misconduct, and other violations, citing the alleged delay in the warrant's issuance and her subsequent public conduct.
  • JIB Recommendation: The Judicial Integrity Board (JIB) investigated the matter and recommended the dismissal of the case for lack of merit, finding no substantial evidence to support the allegations.
  • Supreme Court Review: The case was elevated to the Supreme Court for final resolution.
  • Did Judge Contreras commit Gross Ignorance of the Law by delaying the issuance of the search warrant?
  • Did her uninvited appearance and statements at the congressional hearing constitute misconduct?
  • Was her act of holding a press conference and publishing a letter in the media a violation of judicial ethics?

The Court found Judge Contreras NOT GUILTY of Gross Ignorance of the Law, but GUILTY of two counts of Simple Misconduct.

  • On Delay of Warrant: The Court found no delay. Judge Contreras acted properly by ensuring all legal requisites for a search warrant were met, including conducting searching questions and requiring sufficient evidence for probable cause. The three-hour window was reasonable.
  • On Misconduct (Hearing): Her uninvited appearance and her statements publicly blaming the BFP Chief for the escape of suspects were improper. This conduct eroded public confidence and undermined the dignity and impartiality of the judiciary.
  • On Misconduct (Media): Holding a press conference and publishing letters to the media, even to defend herself, was improper. She should have coordinated with the Supreme Court's Public Information Office (PIO) through the Office of the Court Administrator (OCA).
  • Judicial Propriety (Canon 4, NCJC): Judges must avoid impropriety and the appearance of impropriety in all activities. Their conduct must be consistent with the dignity of the judicial office and preserve public confidence.
  • Simple Misconduct: This is an unacceptable behavior that transgresses established rules of conduct for public officers. It does not require corruption or a clear intent to violate the law, unlike Grave Misconduct.
  • Judicial Media Relations: Judges cannot unilaterally hold press conferences or issue public statements, even to defend themselves. They must coordinate such activities through the proper channels, such as the Supreme Court's Public Information Office (PIO).