Office of the Court Administrator vs. Ruiz

Facts:

The Office of the Court Administrator (OCA) filed an administrative complaint against Judge Joseph Cedrick O. Ruiz, Presiding Judge, RTC, Branch 61, Makati City, after the Sandiganbayan convicted him in Criminal Case Nos. 27467-68 (April 29, 2013) for violation of Section 3(e) of R.A. No. 3019 and for malversation of public funds (Art. 217, Revised Penal Code). The Sandiganbayan imposed indeterminate reclusion temporal sentences, perpetual special disqualification, fines, and indemnity orders. The Sandiganbayan denied respondent’s motions for reconsideration and new trial in its August 28, 2013 resolution.

On October 4, 2013 the OCA transmitted a Report recommending that the Sandiganbayan decision be treated as a formal administrative complaint, that Judge Ruiz be furnished a copy and required to comment, and that he be preventively suspended without pay pending administrative resolution. On October 18, 2013 Judge Ruiz filed a petition for review on certiorari assailing his Sandiganbayan convictions, docketed before the Court as G.R. Nos. 209073-74.

In a November 20, 2013 minute resolution the Court’s Third Division re‑docketed the OCA report as a regular administrative matter, required respondent’s comment, and ordered his preventive suspension without pay effective upon receipt of the resolution. The respondent filed a comment (Jan. 24, 2014) arguing prematurity because his criminal convictions were not final and asserting that he had applied for optional early retirement (effectivity proposed Dec. 31, 2013) and was on leave of absence.

The Supreme Court En Banc treated the OCA report as a formal complaint, conducted an original administrative inquiry applying the substantial‑evidence standard, examined the Sandiganbayan record (witness testimonies of the city budget officer, city treasurer, city accountant, and Police Insp. Pepe Nortal; and documents including the ROA, DV, and PNB check), found that Judge Ruiz facilitated and benefitted from a P1,000,000 withdrawal from the Confiden...(Pro-only)

Issues:

• Is the Court precluded from proceeding administratively because Judge Ruiz’s Sandiganbayan convictions are not yet final?
• Whether substantial evidence exists to hold Judge Ruiz administratively liable for acts committed before his appointment to the bench (facilitating and receiving P1,000,000 CIF withdrawal)?
• What is the appropriate administrative sanction for the respondent if...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

• (Pro-only)

Doctrine:

• (Pro-only)