Title
Baculi vs. Belen
Case
A.M. No. RTJ-11-2286
Decision Date
Feb 12, 2020
Judge Belen found guilty of dishonesty for receiving allowances during suspension; fined Php40,000 and ordered to reimburse Php16,000 to local government units.
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Case Digest (A.M. No. RTJ-11-2286)

Facts:

Background of the Case
Provincial Prosecutor Jorge D. Baculi filed administrative complaints against Judge Medel Arnaldo B. Belen of the Regional Trial Court, Branch 36, Calamba City, Laguna. The complaints included allegations of (a) violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), (b) grave misconduct, (c) disrespect and disobedience to the Supreme Court's decision in A.M. No. RTJ-09-2176, (d) disbarment, (e) contempt of court, and (f) conduct grossly prejudicial to the interest of the government service.

Suspension of Judge Belen
The Supreme Court had previously suspended Judge Belen for six (6) months without salary or benefits for gross ignorance of the law in A.M. No. RTJ-09-2176. The decision was served to Judge Belen on or about May 25, 2009, and his motion for reconsideration was denied on July 15, 2009. Despite this, Judge Belen continued to receive his monthly allowance (honorarium) from the Office of the City Treasurer of Calamba City for June and July 2009.

Allegations of Illegal Receipt of Allowances
Prosecutor Baculi alleged that Judge Belen's receipt of honoraria during his suspension was illegal, fraudulent, and contrary to the principle of "no work, no pay." He argued that Judge Belen's suspension was immediately executory upon receipt of the Court's decision, and thus, he should not have received any benefits during that period. Prosecutor Baculi also accused Judge Belen of refusing to follow the rule of law and disregarding the rulings of the Supreme Court.

Additional Complaints and Evidence
Prosecutor Baculi filed a "New/Additional Complaint" on October 28, 2009, reiterating the allegations and attaching evidence, including payroll records, a special power of attorney, and correspondence with the Office of the Provincial Governor regarding the illegality of the payments.

Judge Belen's Defense
Judge Belen denied all allegations, claiming he had not committed any illegal or unlawful acts. He maintained that his actions were in accordance with the law, rules, and regulations, and that he had not violated his oath as an RTC judge.

OCA's Findings and Recommendations
The Office of the Court Administrator (OCA) found that Judge Belen had indeed received benefits from local government units during his suspension. The OCA recommended that Judge Belen be found guilty of dishonesty and be dismissed from service with forfeiture of his retirement and other benefits, except accrued leave credits.

Further Proceedings
The Supreme Court re-docketed the case as a regular administrative matter and required the parties to manifest if they were willing to submit the case for decision based on the records. Prosecutor Baculi agreed, while Judge Belen sought consolidation with other pending cases, which the Court denied.

Issue:

The primary issue is whether Judge Belen is administratively liable for receiving allowances from the local government during the period of his suspension.

Ruling:

The Supreme Court ruled in the affirmative, finding Judge Belen guilty of dishonesty. The Court emphasized that judges are held to the highest standards of moral righteousness and integrity. By receiving allowances during his suspension, Judge Belen knowingly defrauded the local government units of public funds.

Ratio:

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