Case Digest (IPI No. 15-35-SB-J)
Facts:
The case involves a verified administrative complaint filed by Alfonso V. Umali, Jr., who was the Provincial Administrator of Oriental Mindoro, against Associate Justice Jose R. Hernandez of the Sandiganbayan. The complaint, lodged on July 13, 2015, accused Justice Hernandez of grave misconduct and gross ignorance of the law. Earlier, Umali was one of the accused in Criminal Case No. 23624 related to alleged violations under the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019). On September 9, 2008, the Sandiganbayan's Fourth Division denied a motion to dismiss, leading to Umali and others being convicted and sentenced to an indeterminate penalty and perpetual disqualification from public office in a decision dated April 20, 2015. Justice Hernandez penned this decision, which led Umali to file a motion for reconsideration and later seek voluntary inhibition of Justice Hernandez. Umali claimed he was approached by Ruel Ricafort, a cousin of Justice Hernandez's wife, wCase Digest (IPI No. 15-35-SB-J)
Facts:
Complainant Alfonso V. Umali, Jr., then Provincial Administrator of Oriental Mindoro and one of the accused in a Sandiganbayan criminal case for violating the Anti-Graft and Corrupt Practices Act (RA 3019), filed an administrative complaint against Sandiganbayan Associate Justice Jose R. Hernandez. In the criminal case, Umali and his co-accused were initially convicted and sentenced in a decision later reconsidered by the court, resulting in a reaffirmed conviction in the April 20, 2015 decision. Following his conviction, Umali raised a series of motions, including a motion for reconsideration, a motion for voluntary inhibition of Justice Hernandez, and a motion for leave to admit supplement, all amid mounting discontent with the court’s handling of his case.In his complaint-affidavit, Umali alleged that before the promulgation of the April 20, 2015 decision, a person named Ruel Ricafort – identified as a cousin of Justice Hernandez’s wife – approached a member of Umali’s “camp” and communicated an offer that required Umali to pay ₱15 million in exchange for his acquittal. Umali further claimed that this incident and subsequent remarks by Justice Hernandez during hearings revealed manifest partiality, including favoring Justice Gregory Ong, who was alleged to be a friend of Hernandez. Ultimately, Umali argued that the decision of the Sandiganbayan was tainted by ill will and bias, and that his signing of a voucher should not serve as a basis for a conspiracy finding with his co-accused.
Issues:
- Whether the administrative complaint against Associate Justice Hernandez alleging an extortion attempt and manifest partiality, based primarily on hearsay evidence and surmises, is supported by substantial evidence.
- Whether the allegations stemming from Umali’s dissatisfaction with the collegial Sandiganbayan decision can be appropriately addressed in an administrative proceeding, particularly when concerns involve adjudicative acts rather than disciplinary misconduct.
- Whether the conduct and remarks of Justice Hernandez during the proceedings amount to misconduct or bias sufficient to justify administrative sanctions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)