Case Digest (A.M. No. RTJ-07-2063, RTJ-07-2064, RTJ-07-2066)
Facts:
Republic of the Philippines v. Judge Ramon S. Caguioa, A.M. Nos. RTJ-07-2063, RTJ-07-2064 and RTJ-07-2066, August 23, 2022, the Supreme Court En Banc, Per Curiam, dealt with a petition for judicial clemency filed by former RTC Judge Ramon S. Caguioa. Three administrative matters were consolidated: A.M. No. RTJ-07-2063 (filed by the Republic through the OSG) and A.M. No. RTJ-07-2064 (filed by the Commissioner of Customs) arose from respondent’s issuance of writs of preliminary injunction enjoining implementation of (respectively) Section 6 of R.A. No. 9334 (tax/excise issue in Indigo Distribution Corp., G.R. No. 168584) and a Customs Personnel Order reassigning a district collector; A.M. No. RTJ-07-2066 was a private complainant case (Charles T. Burns, Jr.) accusing respondent of grave misconduct for issuing a writ of execution that placed an adverse party in possession of disputed lands.In a June 26, 2009 Decision the Court found respondent guilty: in A.M. No. RTJ-07-2066 respondent was found guilty of simple misconduct and suspended three months without pay; in A.M. Nos. RTJ-07-2063 and RTJ-07-2064 respondent was found guilty of gross ignorance of the law and conduct prejudicial to the service and was dismissed from the service with forfeiture of retirement benefits except leave credits. That Decision was final and immediately executory; a motion for reconsideration was denied in an August 18, 2009 Resolution and a subsequent omnibus motion was denied December 13, 2011.
Respondent first sought clemency by letter (July 13, 2010) and later, nearly 12 years after dismissal, submitted a Letter‑Request for Judicial Clemency dated February 9, 2021; the Court treated it as a petition for judicial clemency in a March 16, 2021 Resolution and referred it to a commission composed of the three most senior Associate Justices of the Court of Appeals. The Commission (Justices Mariflor P. Punzalan Castillo, Ramon M. Bato, Jr., Apolinario D. Bruselas, Jr.) published notice, required publication and invited opposition; respondent filed proofs of publication and submitted testimonials from Justice Carlito Calpatura (Court of Appeals), Justice Alex L. Quiroz (Sandiganbayan), and Atty. Melencio Sta. Maria (FEU Law Dean). No oppositions were receive...(Pro-only)
Issues:
- Procedural: Was respondent’s February 9, 2021 Letter‑Request properly treated as a petition for judicial clemency and processed in accordance with the Court’s clemency procedures (prima facie evaluation and referral to a fact‑finding commission)?
- Substantive: Did respondent prove, by the applicable standard, that he manifested remorse, reformation, reconciliation, sufficient lapse of time, and promise/potential to merit judicial clemency?
- Remedies: If clemency is warranted in whole or in part, what specific reliefs should be granted — reinstatement, conversion of dismissal to suspension, restoration of retirement ben...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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