Case Digest (A.M. OCA IPI No. 10-21-SB-J)
Facts:
In re: Alleged Immorality and Unexplained Wealth of Sandiganbayan Associate Justice Roland B. Jurado and Clerk of Court IV Mona Lisa A. Buencamino, A.M. OCA. IPI No. 10-21-SB-J, April 04, 2017, Supreme Court En Banc, Mendoza, J., writing for the Court.
An anonymous letter-complaint, originally filed with the Office of the President and copy‑furnished to the Office of the Ombudsman, accused Roland B. Jurado (Associate Justice, Sandiganbayan) and Mona Lisa A. Buencamino (Clerk of Court IV, Metropolitan Trial Court, Caloocan City) of unexplained wealth and immorality. The Ombudsman referred the matter to the Supreme Court, which, by Resolution dated February 2, 2010, directed the Office of the Court Administrator (OCA) to conduct a discreet investigation.
The OCA empanelled a team of lawyers and personnel to investigate (March 8–31, 2010). The OCA’s December 9, 2016 Memorandum reported that both respondents owned multiple real properties in Metro Manila; that Justice Jurado’s SALNs for 2000–2005 and 2008 understated properties (with missing 2006–2007 SALNs); and that Atty. Buencamino’s SALNs contained alleged inconsistencies. The OCA also flagged as irregular the co-ownership of TCT No. T-23272 (a Las Piñas parcel) by Justice Jurado and Atty. Buencamino, noting Justice Jurado’s marital status.
Respondents filed comments and explanations. Justice Jurado explained that many Las Piñas titles derived from a single “mother” title (TCT No. T-23266) and that several tax declarations were improvements on the same lots; he said some parcels had been sold (e.g., TCT No. T-23269 and PT-104972) and produced deeds, promissory notes, loan documents and receipts showing legitimate acquisition and financing. He denied any immoral relationship with Atty. Buencamino and described a lawful buy‑develop‑sell business venture with her, with his spouse’s knowledge and consent.
Atty. Buencamino admitted owning the properties and explained many items as inherited, acquired legitimately, or developed from family land; she alleged one tax declaration (TD E‑011‑09204) in the OCA file was altered and submitted a certified copy to support that claim. She also invoked an earlier NBI inquiry (2002) and a prior Ombudsman referral concerning similar charges, whose investigative report found her earnings from real‑estate activities augmented her legitimate income.
The Court reviewed the ...(Subscriber-Only)
Issues:
- Was there substantial evidence to sustain administrative charges of unexplained wealth and immorality against Justice Roland B. Jurado and Atty. Monalisa A. Buencamino?
- Were the discrepancies in the respondents’ SALNs and the co‑ownership of TCT No. T-23272 sufficient to establish unexplained ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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