Title
Arabani, Jr. vs. Arabani
Case
A.M. No. SCC-10-14-P, SCC-10-15-P, SCC-11-17
Decision Date
Nov 12, 2019
Administrative complaints against Judge Arabani and court personnel; after Clerk of Court Ramos' death, suspension penalty converted to a fine, moot charges dismissed.

Case Summary (A.M. No. SCC-10-14-P, SCC-10-15-P, SCC-11-17)

Jurisdiction

The letter dated June 20, 2019, from the surviving spouse of Rodrigo Ramos, Jr. informed the Court of his death on December 5, 2016, and requested a modification of his administrative penalty from suspension to a fine. The Court confirmed its jurisdiction in administering this case despite Ramos’s demise, asserting that jurisdiction over administrative proceedings does not cease with the death of the respondent, especially when the individual had already answered the complaint.

Administrative Case Proceedings

The Court referenced previous cases confirming its authority to adjudicate the merits of the administrative complaint against a deceased official. It specified that allowing the dismissal of the case would lead to undesirable precedents and injustices. The Court retained the power to declare the respondent innocent or guilty based on the evidence and arguments presented prior to Ramos's passing.

Modification of Penalties

In light of Ramos’s death, the Court noted it was no longer possible to impose a suspension as a penalty. Instead, referring to past decisions, the Court determined that a fine of Twenty Thousand Pesos (P20,000.00) should be substituted in place of the earlier suspension for the charge of frequent unauthorized absences, reinforced by similar cases where penalties were adjusted posthumously.

Dismissal of Charges

Additionally, the original decision penalized Ramos for violating reasonable office rules and regulations, which was deemed a lighter infraction. However, since Ramos was no longer available to be reprimanded or sanctioned, this charge was recorded as moot and

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