Unpaid IBP dues cost judge P200K

The Supreme Court has ordered a regional trial court judge in Abra to pay a total of P200,000 in fines for failing to settle his Integrated Bar of the Philippines (IBP) dues for 18 straight years, from 2004 to 2021.

Judge Corpus Alzate of the Bangued Regional Trial Court was found guilty of simple misconduct, a less serious offense under the New Code of Judicial Conduct, and fined P150,000. He was also penalized an additional P50,000 as a lawyer for violating the Code of Professional Responsibility and Accountability.

In a decision penned by Associate Justice Amy Lazaro-Javier on October 29, 2024, the Court emphasized that all IBP members, including judges, are obligated to pay their annual dues before 31 December of each fiscal year.

“There is nothing in the law or rules which allows the exemption of any person — much more for members of the bench such as Judge Alzate — from payment of IBP dues,” the ruling stated.

A complaint had accused Alzate of knowingly avoiding payment of his dues for nearly two decades. Upon learning of the complaint, Alzate said he immediately requested a breakdown of his arrears and paid P23,100 to settle the balance from 2004 to 2021.

The Supreme Court ruled that his own admission was enough to establish liability.

In his defense, Alzate explained that early in his career, he was told by fellow IBP members that a candidate in the IBP elections had covered dues for members. He also claimed that on occasions when he did pay, the IBP Abra Chapter failed to remit the payments to the national office, and although he was told the records would be reconciled, this never happened. Eventually, he admitted, he forgot about the dues altogether.

Alzate also said a fellow judge had advised him that unpaid IBP dues would simply be deducted from his retirement pay or earned leave credits, so he assumed the matter would be settled eventually.

But the Supreme Court ruled that his own admission was enough to establish liability. The justices said his failure to fulfill his professional obligations undermines public confidence in the judiciary, stressing that judges must uphold the highest ethical standards and avoid even the appearance of impropriety.

The Court warned that any similar offense in the future will be dealt with more severely and ordered Alzate to immediately update his IBP membership dues.