Case Digest (A.M. No. RTJ-15-2438)
Case Digest (A.M. No. RTJ-15-2438)
Facts:
Sharon Flores-Concepcion v. Judge Liberty O. Castaneda, A.M. No. RTJ-15-2438 (Formerly OCA I.P.I. No. 11-3681-RTJ), September 02, 2020, Supreme Court En Banc, Leonen, J., writing for the Court.
The complainant, Sharon Flores-Concepcion, alleged that her marriage to Vergel Concepcion had been declared void ab initio by a July 30, 2010 Decision in Civil Case No. 459-09 of the Regional Trial Court (RTC), Branch 67, Paniqui, Tarlac, presided by Judge Liberty O. Castaneda, even though she never knew of any petition or proceedings. Upon inspecting Branch 67 on December 8, 2010, Concepcion discovered the records reflected no hearing had been conducted and that she had not been properly served; she filed a Petition for Relief from Judgment (January 19, 2011) and a Complaint‑Affidavit against Judge Castaneda.
The Office of the Court Administrator (OCA) directed Judge Castaneda to comment (June 29, 2011), but she ignored the order. Separately, in 2012 Judge Castaneda had already been the subject of a different administrative case (Office of the Court Administrator v. Judge Liberty O. Castaneda, A.M. No. RTJ-12-2316), in which this Court dismissed her from service for dishonesty, gross ignorance of the law and procedure, gross misconduct and incompetency, and forfeited her retirement benefits except accrued leave credits.
The OCA initially recommended dismissal of Concepcion’s complaint because of the 2012 decision, but the Court returned the matter to the OCA for re-evaluation. In a July 7, 2015 Memorandum the OCA found that Judge Castaneda had willfully and contumaciously disregarded laws and rules in disposing of the nullity case with procedural defects, noted her refusal to comment, and recommended: (1) re‑docketing the matter as a regular administrative complaint; (2) finding her guilty of gross ignorance of the law and imposing dismissal with forfeiture of benefits (had she not already been dismissed in 2012); and (3) disbarment for violations of the Code of Professional Responsibility. While the OCA memorandum was pending, Judge Castaneda died on April 10, 2018.
The sole question presented to the Court was whether respondent Judge Castaneda’s death during pendency required dismissal of the administrative complaint. The Court considered its prior rulings — notably the sequence in Re: Investigation Report on the Alleged Extortion Activities of Presiding Judge Godofredo B. Abul, Jr. (A.M. No. RTJ‑17‑2486) — and a line of jurisprudence on administrative due process, the impracticability of imposing penalties after death, and exceptions where proceedings may properly continue.
This administrative matter was resolved by the Supreme Court En Banc on the petition docket (administrative docket A.M. No. RTJ-15-2438), with the majority opinion by Justice Leonen and separate concurring and dissenting opinions filed.
Issues:
- Does the death of a respondent judge during the pendency of an administrative case render the case moot and warrant dismissal?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)