Title
Rosal vs. Salvador
Case
A.C. No. 236-J
Decision Date
Aug 30, 1974
Judge Joaquin M. Salvador was accused of misconduct for alleged partiality and negligence in a PCSO-related case and his son-in-law’s employment; the Supreme Court dismissed the complaint due to lack of evidence.

Case Summary (A.C. No. 236-J)

Allegations of Misconduct

The core of the complaint is rooted in the assertion that Judge Salvador displayed bias and engaged in impropriety related to his familial ties. Specifically, it is alleged that he appointed his son-in-law, Reynaldo Legaspi, to positions at the PCSO while a significant case (CIR Case 280 INJ) concerning the union's strike actions was pending before him. The complaint claims that Salvador's actions constituted a violation of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019), particularly Sections 3(d), (e), and (f), which pertain to conflicts of interest, undue advantage to private parties, and neglect of duty.

Judge’s Response to Allegations

In a written response dated April 17, 1972, Judge Salvador denied awareness of his son-in-law's employment status at the PCSO during the case. He attributed Legaspi’s appointment to the recommendation of a Congressman, Eduardo Cojuangco, Jr., stating that this recommendation was based on a long-standing friendship. Salvador also contended that the reasoning for declaring the strike illegal was adequately documented in his order and was under reconsideration by the Court en banc at that time. He further denied the allegations regarding neglecting to act on the petition to suspend execution of his order.

Investigation and Findings

The matter was subsequently referred to Associate Justice Ramon G. Gaviola, Jr., who conducted an investigation and submitted a report on July 3, 1973. His findings concluded that there was insufficient evidence to support the claims that Judge Salvador had influenced the employment of his son-in-law at the PCSO. Furthermore, the investigation did not substantiate any allegations of partiality, bad faith, or negligence in connection with the judge's rulings regarding the labor dispute. The legality of Salvador's order declaring the strike illegal was affirmed by the Court of Industrial Relations en banc, reinforcing the validity of his actions.

Conclusion and Dismissal of Case

The Court accepted the findings and recommendations of Associate Justice Gaviola. Based on the lack of merit in the alle

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