SC warns judge over behavior during parking dispute

A Marikina City Regional Trial Court judge was warned by the Supreme Court (SC) for his conduct during a parking-related incident involving a Public Attorney’s Office (PAO) lawyer, which was shared on social media.

In a decision written by Associate Justice Jhosep Y. Lopez dated 1 July 2025, the SC En Banc found that Judge Rey P. Inciong acted improperly when he publicly scolded PAO lawyer Atty. Ivanheck U. Gatdula and demanded a public apology.

The administrative case arose from a social media post showing Judge Inciong shouting at Atty. Gatdula inside the Marikina Hall of Justice.

The incident began when Atty. Gatdula’s vehicle briefly blocked an access ramp for persons with disabilities (PWD) and a pedestrian pathway while he logged his attendance to avoid being marked late. Atty. Gatdula immediately apologized several times.

Despite this, Judge Inciong demanded a public apology and later went to the PAO office, where he again insisted on the apology and lost his temper. Gatdula and his supervisor described the judge’s remarks and actions as intimidating and unnecessary, noting that a public apology was no longer required.

The Office of the Court Administrator ordered Judge Inciong to explain his actions and initially recommended that he be reprimanded and sternly warned. The case was referred to the Judicial Integrity Board (JIB), which found him guilty of the light offense of vulgar and unbecoming conduct under Canon VI, Section 35(b) of the Code of Professional Responsibility and Accountability (CPRA).

The SC acknowledged Judge Inciong’s intention to enforce order in the Hall of Justice but emphasized that it did not justify harsh language or aggressive behavior. Citing Canons II (Integrity) and IV (Propriety) of the CPRA, the SC reminded judges that even when faced with improper conduct, they must act with restraint and maintain the dignity of their office. Public confidence in the judiciary depends on how judges behave, the court said.

The SC noted that judges may exercise their right to free speech, but it must be within the limits of decency. The court also observed that this was Judge Inciong’s first offense and that he has maintained a clean record in public service since 1999. While the SC found him free from administrative liability, it warned that future similar behavior could result in more serious consequences.

Associate Justice Japar B. Dimaampao agreed with the JIB’s recommendation that Judge Inciong be held liable for using vulgar or offensive language. He added that the judge should also be held liable for simple misconduct under the CPRA and for gravely prejudicial conduct under Rule 140 of the Rules of Court due to his rude and aggressive behavior toward Atty. Gatdula.