Case Title:
Guanzon v. Rufon
A.M. No. RTJ-07-2038 (Formerly A.M. OCA IPI No. 05-2250-RTJ), October 19, 2007
Parties:
Complainant: Atty. Rowena V. Guanzon – a practicing lawyer and gender advocate.
Respondent: Judge Henry E. Rufon – Presiding Judge of the Regional Trial Court, Branch
46, Bacolod City.
Facts:
Atty. Guanzon filed a complaint against Judge Rufon for using sexist and gender-biased
language in a decision he penned in a criminal case.
In his written decision, Judge Rufon made comments describing women in a derogatory
and demeaning manner, particularly about their physical appearance, sexual behavior,
and morality, which had no relation to the merits of the case.
The complainant stressed that the judge’s words reflected gender insensitivity and
reinforced negative stereotypes about women.
She argued that such behavior violated the Code of Judicial Conduct, the constitutional
mandate of gender equality, and the principle of gender-fair language under laws and
international conventions binding the Philippines (CEDAW, Beijing Platform for Action,
Magna Carta of Women).
Issue:
Whether or not Judge Rufon should be held administratively liable for using sexist, gender-
insensitive, and derogatory language in a judicial decision.
Ruling of the Court:
The Supreme Court found Judge Rufon administratively liable.
It ruled that judges, as dispensers of justice, must always conduct themselves in a
manner that promotes respect for women and men alike, free from prejudice and
gender bias.
The Court emphasized that:
o Judges are bound by the Code of Judicial Conduct, which requires them to act
with propriety, integrity, and impartiality.
o Using language that demeans or stereotypes women is improper and
inconsistent with the constitutional guarantee of equality before the law.
o Courts are institutions of justice, and their decisions must embody fairness,
sensitivity, and respect, especially toward marginalized or historically
discriminated groups such as women.
Judge Rufon was reprimanded and warned that repetition of the same or similar acts
would be dealt with more severely.
Gender and Development (GAD) and Gender-Fair Language Perspective:
The case highlights the importance of gender sensitivity in the judiciary, particularly in
the use of language.
Language is not neutral; sexist remarks by judges perpetuate discrimination and
undermine women’s dignity.
The ruling reinforces:
o CEDAW (Convention on the Elimination of All Forms of Discrimination Against
Women) obligations.
o The Philippine Constitution, Art. II, Sec. 14, which recognizes the role of women
and ensures the fundamental equality before the law of women and men.
o The policy direction later codified in the Magna Carta of Women (RA 9710)
promoting gender-fair language in government, law, and public discourse.
Thus, Guanzon v. Rufon became a landmark case in promoting gender-fair language
within the Philippine judiciary.
Case Title:
Espejon and Cabonita v. Hon. Judge Jose B. Lorredo
A.M. No. MTJ-22-007, March 9, 2022
Parties and Relationships:
Respondent:
o Judge Jose B. Lorredo – Presiding Judge, MTCC Cebu City, Branch 3.
o Holds direct authority over the complainants, as their immediate superior in the
court.
Complainants:
1. Atty. Ma. Cristina C. Espejon – Clerk of Court of the same branch.
Works directly under Judge Lorredo, tasked with supervising personnel,
managing case records, and ensuring smooth court operations.
Her position requires frequent interaction with the judge.
2. Ms. Charisse Cabonita – Court Legal Researcher.
Also under the supervision and authority of Judge Lorredo.
Works on legal drafts and research directly related to the judge’s
functions.
Relationship Dynamics:
o Both complainants are subordinates of the judge, making them vulnerable to his
authority.
o The power imbalance between the judge (as appointing and disciplining
authority in the branch) and the complainants created an environment where his
remarks and conduct could not be freely resisted.
o This dynamic aggravated the impact of his sexist and harassing behavior, as
employees feared retaliation or adverse career consequences if they objected.
Facts:
The complaint stemmed from a pattern of inappropriate behavior by Judge Lorredo
toward his female subordinates, particularly Atty. Espejon and Ms. Cabonita.
Specific acts included:
o Unwelcome remarks about women’s physical appearance, including sexual
innuendos and degrading comments not related to their work.
o Inappropriate jokes and gestures that made female staff uncomfortable.
o Creating a hostile workplace environment where women employees felt
objectified rather than respected as professionals.
The complainants filed a formal administrative case, citing not only their personal
experiences but also the broader violation of workplace dignity and gender rights.
They stressed that his actions undermined the principles of gender equality and fairness
promoted by the Constitution and various gender-related laws.
The Office of the Court Administrator (OCA) investigated and confirmed the complaints,
recommending administrative sanctions.
Issue:
Whether Judge Lorredo is administratively liable for sexual harassment, use of sexist and
gender-insensitive language, and conduct unbecoming of a judge in violation of the Code of
Judicial Conduct and gender development principles.
Ruling of the Court:
YES. The Supreme Court ruled that Judge Lorredo was guilty of sexual harassment and
improper conduct.
Penalty:
o Dismissal from the service.
o Forfeiture of all retirement and benefits, except accrued leave credits.
o Perpetual disqualification from reemployment in any branch or agency of
government, including government-owned or controlled corporations.
Reasoning:
o The acts of Judge Lorredo constituted sexual harassment as defined under R.A.
No. 7877 (Anti-Sexual Harassment Act of 1995).
o His remarks and behavior violated the Code of Judicial Conduct, particularly the
canons on propriety, integrity, and impartiality.
o By making sexist, objectifying, and offensive statements, he failed to maintain
the dignity of his judicial office.
o His actions perpetuated a gender-insensitive environment, which is
unacceptable in an institution tasked with upholding justice.
Gender and Development (GAD) and Gender-Fair Language Perspective:
The Court underscored that judges, as symbols of justice, must be paragons of gender
sensitivity.
The use of sexist remarks and objectification of women in the workplace directly
undermines the principles of gender equality enshrined in:
o 1987 Constitution, Art. II, Sec. 14 (state recognizes the role of women and
ensures fundamental equality before the law).
o R.A. No. 7877 (Anti-Sexual Harassment Act of 1995).
o R.A. No. 9710 (Magna Carta of Women).
o CEDAW (Convention on the Elimination of All Forms of Discrimination Against
Women).
The ruling also aligned with the judiciary’s policy of promoting Gender and
Development (GAD) mainstreaming, particularly in ensuring a safe, fair, and respectful
workplace.
The case is a reaffirmation that language matters: when those in power use words that
demean women, it normalizes discrimination and inequality. Thus, courts must practice
gender-fair language as part of upholding justice.
Summary:
The Supreme Court dismissed Judge Lorredo for sexually harassing his female subordinates,
Atty. Espejon and Ms. Cabonita, through sexist language and inappropriate conduct. The Court
stressed that judges must uphold the highest standards of propriety, observe gender
sensitivity, and use gender-fair language. The case stands as a landmark in integrating GAD
principles and workplace gender equality in the judiciary.
Case Title:
Re: Laarni N. Dajao
A.M. No. RTJ-16-2456, March 2, 2020
Parties:
Complainant:
o Laarni N. Dajao – the court stenographer who filed the complaint.
Respondent:
o Judge Florentino D. Dinopol – Presiding Judge, RTC Branch 24, Koronadal City.
o Superior of the complainant and had direct authority over her as part of the
court personnel.
Facts:
The case stemmed from remarks and behavior of Judge Dinopol directed at Ms. Laarni
Dajao, which she found demeaning, sexist, and violative of her dignity as a woman.
Ms. Dajao complained that Judge Dinopol made sexually suggestive and inappropriate
remarks in open court and in the workplace.
Among the statements attributed to the judge were:
o “Ang babae, parang damit. Kapag luma na, dapat palitan ng bago.” (“A woman
is like clothing. When she is old, she should be replaced with a new one.”)
o Remarks comparing women to toys and objects, trivializing their worth and role.
o Innuendos on women’s looks and sexuality, often made in front of other court
personnel, which caused embarrassment and humiliation.
The complainant alleged that these remarks created a hostile and gender-insensitive
environment in the court, undermining her integrity as a professional.
The Office of the Court Administrator (OCA) investigated the complaint.
Issue:
Whether Judge Dinopol should be held administratively liable for making sexist, gender-
insensitive, and demeaning remarks against women, in violation of the Code of Judicial
Conduct and GAD principles.
Ruling of the Court:
The Supreme Court found Judge Dinopol administratively liable for grave misconduct
and violation of the New Code of Judicial Conduct for the Philippine Judiciary.
He was found guilty of making sexist and offensive remarks that demeaned women and
reduced them to stereotypes.
Penalty: Judge Dinopol was dismissed from the service, with:
o Forfeiture of all retirement benefits (except accrued leave credits).
o Perpetual disqualification from reemployment in any government branch,
subdivision, or instrumentality.
Reasoning of the Court:
Judges must exhibit the highest standards of propriety and decorum, both in official
capacity and in personal dealings.
The remarks made by Judge Dinopol reflected sexist bias and were grossly improper,
especially since they were uttered in the court setting where women must feel secure,
respected, and treated with dignity.
By likening women to objects (clothes, toys, commodities), he violated:
o Canon 2, Section 1 of the New Code of Judicial Conduct – judges must avoid
impropriety and the appearance of impropriety in all activities.
o Canon 4, Section 2 – judges must ensure equality of treatment to all before the
courts.
His acts undermined the constitutional guarantee of gender equality (Art. II, Sec. 14,
1987 Constitution).
Gender and Development (GAD) and Gender-Fair Language Perspective:
The decision underscores that words have power—when judges make sexist remarks,
they normalize discrimination.
The ruling reinforced:
o R.A. 9710 (Magna Carta of Women): State must eliminate discrimination against
women in all spheres, including language and workplace practices.
o R.A. 7877 (Anti-Sexual Harassment Act): Protects women from gender-related
verbal harassment in the workplace.
o CEDAW (Convention on the Elimination of All Forms of Discrimination Against
Women): Obliges the Philippines to eliminate prejudices based on stereotyped
roles of men and women.
The Court declared that the judiciary must be a model institution in using gender-fair
language and in creating a workplace that is safe and respectful for women.
Summary:
Judge Dinopol was dismissed from service for making sexist, objectifying, and derogatory
remarks about women such as likening them to clothes and toys. The Court emphasized that
judges must practice gender-fair language and uphold gender sensitivity as part of their judicial
duty. The ruling reinforced the judiciary’s commitment to gender equality and GAD
mainstreaming, ensuring that women are treated with dignity and respect in all judicial
settings.
