A.M. No. SCC-10-14-P, SCC-10-15-P, SCC-11-17

The case involves multiple administrative proceedings before the Supreme Court en banc concerning actions of public officials from the Shari’a Circuit Court in Maimbung, Sulu.
A letter dated June 20, 2019, was submitted by the surviving spouse of Rodrigo Ramos, Jr., informing the Court of his death on December 5, 2016.
The petition sought a modification of the penalty imposed against Rodrigo, particularly requesting that the suspension penalty be reduced to a fine in light of his demise.

Previously, in the Decision dated February 21, 2017 in A.M. No. SCC-10-15-P (Formerly A.M. No. 06-3-03-SCC), Rodrigo was found guilty of:

Frequent unauthorized absences, including loafing or absence from duty during regular office hours.
Violation of reasonable office rules and regulations.

The penalty imposed was a suspension of six (6) months and one (1) day without pay, along with a reprimand for the violation of office rules.
It is important to note that prior to the submission of the letter informing of his death, Rodrigo had been given the opportunity to answer and substantiate his defenses in the administrative cases.

The letter by the surviving spouse was critical because it raised the issue of administering penalties after the respondent’s death.
The Court had already rendered a decision against him when his death was reported.
This raised the procedural issue regarding the applicability of penalties such as suspension or reprimand when the respondent is no longer in active government service.

The Court referenced prior cases, such as those in Office of the Ombudsman v. Pacuribot and Office of the Court Administrator v. Saguyod, which upheld that administrative jurisdiction remains effective despite the respondent’s death, provided that the respondent had an opportunity to be heard.
A previous similar instance where a public official, found guilty of unauthorized absences but already separated from service at the time of promulgation, was fined an amount (P20,000.00) instead of imposing suspension.
The outcome in the previous case served as a guiding precedent for the current resolution.

Whether the Court retains jurisdiction over an administrative case when the respondent public official dies after being given the opportunity to answer the complaint and substantiate his defenses.

Whether the penalty of suspension (six months and one day without pay) remains applicable after the respondent's demise.
Whether the sanction for violation of office rules and regulations, which originally warranted a reprimand, should still be applied when it becomes moot and academic due to the death of the respondent.

Whether substituting the suspended penalty with a financial fine is proper and consistent with established precedents.
Whether dismissing the charge for violation of reasonable office rules is justified given that the corresponding reprimand is no longer practicable posthumously.