Case Digest (A.M. No. 2019-17-SC)
Facts:
This administrative case arises from a complaint filed by Dr. Virgilio Rodil against Atty. Andrew C. Corro, which subsequently implicated Samuel L. Ancheta, Jr., and Imelda Posadas. The allegations stem from events related to a petition for review before the Supreme Court, specifically G.R. No. 205227. Dr. Rodil, acting on behalf of Atty. Ramel Aguinaldo, sought assistance from Posadas, a Records Officer II at the Court of Appeals, to aid in securing a favorable judgment. Posadas contacted Ancheta, a Records Officer III at the Office of the Division Clerk of Court of the Supreme Court.
Ancheta, upon inquiring about the case, learned from Atty. Corro that the case had been raffled to Associate Justice Martin S. Villarama. Allegations surfaced that Atty. Corro then demanded a bribe of Php10,000,000.00 in exchange for a favorable judgment in the case involving Marco Alejandro, charged with illegal sale of dangerous drugs. This bribe was conveyed through a chain of intermediaries—
Case Digest (A.M. No. 2019-17-SC)
Facts:
- Background and Origin of the Case
- A complaint was filed by Dr. Virgilio Rodil before the Office of the Bar Confidant concerning the conduct of Atty. Andrew C. Corro, with Samuel L. Ancheta, Jr. and Imelda Posadas also implicated.
- Dr. Rodil acted on behalf of Atty. Ramel Aguinaldo, whose client had a pending petition for review before the Court.
- In an effort to secure a favorable ruling for the petition, Dr. Rodil utilized his contacts within the judiciary.
- Involvement of Court Personnel and the Flow of Transactions
- Imelda V. Posadas, a Records Officer II at the Reporters Office of the Court of Appeals, was approached by Dr. Rodil for assistance.
- Posadas connected Dr. Rodil with Samuel L. Ancheta, Jr., a Records Officer III at the Office of the Division Clerk of Court, Third Division, Supreme Court.
- Ancheta made inquiries regarding the status of the case and identified that the case was raffled to Associate Justice Villarama, prompting him to involve Atty. Andrew C. Corro by asking if he could “review” the matter.
- The Bribery Scheme and Transaction Details
- Atty. Corro demanded a bribe of Php10,000,000.00 in exchange for drafting a favorable decision to acquit Marco Alejandro in a drug-related case.
- The bribe was transmitted in four distinct installments:
- First installment of Php800,000.00 on April 22, 2013, delivered through a chain from Dr. Rodil to Posadas, then to Ancheta, and finally to Atty. Corro.
- Second installment of Php700,000.00 on August 12, 2013, via the same chain of intermediaries.
- Third installment of Php5,000,000.00 on December 13, 2013, delivered by Dr. Rodil during a personal meeting with Atty. Corro and his friend, Rico Alberto.
- Fourth installment of Php3,500,000.00 on February 21, 2014, given directly by Dr. Rodil to Atty. Corro, witnessed by Alberto.
- A favorable “decision” was later issued by the Court; however, it was revealed to be fictitious, prompting further action.
- Administrative Investigation and Recommendations
- The Supreme Court’s Office of Administrative Services (SC-OAS) conducted an investigation into the role of Samuel L. Ancheta, Jr.
- In a Memorandum dated November 5, 2019, the SC-OAS, through Atty. Maria Carina M. Cunanan, recommended that Ancheta be found guilty of grave misconduct.
- The investigation revealed that Ancheta actively participated in verifying case status, facilitating contacts between Dr. Rodil and Atty. Corro, delivering the bribe money, and acting as a facilitator during meetings—all during official working hours.
- It was noted that Ancheta’s involvement was pivotal to the transactions, and his 38 years of service in the Court did not absolve him from accountability but rather served as an aggravating factor.
- Impact on the Judiciary and Broader Context
- The acts of Samuel L. Ancheta, Jr. led to a significant erosion of public trust and confidence in the judiciary.
- The case underscored the importance of maintaining high ethical standards and the image of impartial justice within the courts.
- The administrative findings were situated within a broader context of cases involving breaches of the Code of Conduct for Court Personnel and instances of corruption.
Issues:
- Whether the actions of Samuel L. Ancheta, Jr., in facilitating the bribery scheme, constituted grave misconduct under the established norms and rules governing court personnel.
- Was Ancheta’s active involvement in the bribery transactions and subsequent facilitation of a fictitious favorable decision in violation of the Code of Conduct for Court Personnel?
- Did Ancheta’s conduct reflect an abuse of his official position in a manner that undermined the integrity of the judiciary?
- The significance of length of service in evaluating the offense
- Whether Ancheta's long tenure (38 years) in the Court should mitigate or aggravate the gravity of his actions.
- How does the precedent regarding service length play into justifying disciplinary measures in cases of serious misconduct?
- The appropriateness of the penalties imposed
- Whether the dismissal from service and the forfeiture of retirement benefits (except accrued leave credits) are justified based on the nature of the offense.
- The role that public perception and trust in the judicial system played in determining the magnitude of the penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)