G.R. No. A.M. No. 783-MJ October 8, 1974
JUAN DE LA CRUZ, complainant, vs. JUDGE GLICERIO ARENAL, Municipal Judge of Quezon, Quezon, respondent.

FACTS

In an undated and unverified letter-complaint addressed to the President of the Philippines, a certain Juan de la Cruz charged Municipal Judge Glicerio Arenal of Quezon, Quezon, with multiple administrative offenses including extortion, grave misconduct, habitual drunkenness, neglect of duty, and oppression. This complaint was referred to the respondent judge for his comment. On November 27, 1972, Judge Arenal submitted his answer, denying all accusations as false, malicious, and unfounded.
Subsequently, on September 28, 1973, the Assistant Executive Secretary informed the Secretary of Justice that the President had accepted the resignation of Atty. Glicerio Arenal as Municipal Judge, effective immediately. This was formally communicated to the respondent via a telegram from the Secretary of Justice on October 11, 1973, advising him to vacate his position upon receipt thereof.

ISSUE

Whether the administrative complaint against the respondent judge should be dismissed following his resignation from office and the acceptance thereof by the President.

RULING

Yes, the administrative complaint is dismissed. The Supreme Court based its ruling on two primary legal grounds. First, the initiating letter-complaint was procedurally defective as it was not verified, thereby failing to comply with the formal requirements prescribed under Section 1, Rule 140 of the Rules of Court and/or Section 32, Article VII of Republic Act No. 2260 , as amended. A verified complaint is a fundamental procedural requisite in administrative proceedings against judges to ensure seriousness and accountability from the complainant.
Second, and more decisively, the Court ruled the case had become moot and academic. The respondent had ceased to be a member of the judiciary following the acceptance of his resignation by the President. The Court cited its consistent jurisprudence, referencing prior resolutions in analogous administrative cases (e.g., Gaudiano Calagan vs. Rosendo Gabriel and Jose Viado, et al. vs. Teofilo N. Tumulak), where it dismissed administrative complaints against judges whose resignations had been accepted. The rationale is that the primary purpose of administrative discipline is to protect the public service and the judiciary by purging unfit officers. Once a judge resigns and the resignation is accepted, he is no longer subject to the Court’s administrative authority, and any further disciplinary action serves no practical purpose, as the objective of his removal from office has already been achieved. Consequently, the complaint against Ex-Municipal Judge Glicerio Arenal was dismissed and considered terminated.