G.R. No. 209073-74. February 2, 2016.
Office of the Court Administrator, Complainant, vs. Presiding Judge Joseph Cedrick O. Ruiz, Regional Trial Court, Branch 61, Makati City, Respondent.

FACTS

The Office of the Court Administrator (OCA) filed an administrative complaint against respondent Judge Joseph Cedrick O. Ruiz following his conviction by the Sandiganbayan for violation of Section 3(e) of R.A. No. 3019 and Malversation of Public Funds. The criminal cases stemmed from his actions as then City Mayor of Dapitan City, where he was found to have conspired with a police officer to facilitate a P1 million cash advance from the city’s Confidential and Intelligence Fund for his personal benefit. The Sandiganbayan imposed penal sentences, perpetual special disqualification, and ordered him to pay fines and indemnity.
Judge Ruiz moved for reconsideration and a new trial, which were denied. He subsequently filed a petition for review on certiorari with the Supreme Court, assailing his conviction. Meanwhile, the OCA recommended the administrative case be re-docketed, arguing that conviction for a crime involving moral turpitude is a serious charge warranting preventive suspension and potential dismissal, notwithstanding the pending appeal.

ISSUE

Whether respondent Judge Joseph Cedrick O. Ruiz may be held administratively liable and dismissed from service based on his conviction by the Sandiganbayan for crimes involving moral turpitude, despite the pendency of his appeal.

RULING

Yes. The Supreme Court En Banc dismissed Judge Ruiz from service. The Court held that its constitutional power of administrative supervision over judges is separate from criminal proceedings. A criminal conviction, even if not yet final due to a pending appeal, constitutes sufficient basis for administrative discipline if the crime involves moral turpitude. Violation of the Anti-Graft and Corrupt Practices Act and Malversation are crimes that inherently involve moral turpitude, as they constitute acts of dishonesty and betrayal of public trust.
The logic is that the standard of integrity required of members of the judiciary is stringent. The administrative case is not meant to re-litigate the criminal conviction but to determine the respondent’s fitness to remain in office based on the evidence already presented and adjudged in the criminal case. The Sandiganbayan’s detailed findings, which established the respondent’s active participation in the fraudulent scheme, provided more than ample basis for administrative liability. His actions demonstrated a blatant disregard for the law and ethical standards, rendering him unfit to discharge judicial functions. His separation from the service is thus imperative to preserve public confidence in the judiciary.