A.M. No. 141-MTJ / A.M. No. R-478-MTJ. August 26, 1986.
RE: CONVICTION OF MUNICIPAL CIRCUIT JUDGE AMANDITO D. ARANETA BY THE SANDIGANBAYAN; SANCHO BALAYON, ET AL. vs. HON. AMANDITO D. ARANETA.

FACTS

This administrative matter consolidates two cases against Municipal Trial Court Judge Amandito D. Araneta. The first, A.M. No. 141-MTJ, originated from the Sandiganbayan’s final decision in Criminal Case No. 7220, convicting Judge Araneta beyond reasonable doubt of the crime of Infidelity in the Custody of Prisoners. The Sandiganbayan found that for about five months, the judge misused his office by having detention prisoners perform domestic chores and carpentry work at a store he owned beside his house. The prisoners were unguarded, and custody was formally transferred to him per police logs. On December 1, 1979, he ordered three prisoners to return to jail unsupervised, enabling one charged with Murder and Double Frustrated Murder—pending in his own court—to escape.
The second case, A.M. No. R-478-MTJ, involved a complaint from the Peace & Order Council of Norala, South Cotabato, alleging Ignorance of the Law, Oppressive Acts, and Partiality. Specific allegations included dismissing a criminal case without arraignment or trial, initially refusing to act on a complaint involving a death, and imposing an excessive bail bond for an escapee. The Council sought his immediate relief or dismissal.

ISSUE

Whether respondent Judge Amandito D. Araneta should be dismissed from the judicial service based on his criminal conviction and the separate administrative charges.

RULING

Yes, respondent Judge is ordered dismissed from the service. The Court, per curiam, ruled that the criminal conviction by the Sandiganbayan for Infidelity in the Custody of Prisoners is by itself a sufficient and compelling ground for administrative sanction. The factual findings of the Sandiganbayan, which attained finality, conclusively established that Judge Araneta gravely abused his authority. His act of using detention prisoners for personal labor and allowing them to move without guard, directly resulting in the escape of a seriously charged individual, constitutes conduct grossly prejudicial to the administration of justice. This behavior demonstrates a blatant disregard for the sanctity of judicial office and the legal custody of prisoners, rendering him utterly unfit to remain a judge.
The Court found it unnecessary to exhaustively evaluate the separate allegations in A.M. No. R-478-MTJ, as the conviction provided an indubitable basis for dismissal. His failure to file an answer to the administrative charge further underscored his lack of defense. Consequently, his actions warranted the supreme penalty. Judge Araneta was dismissed from service with forfeiture of all retirement benefits and pay, with prejudice to reinstatement in any government branch, agency, or instrumentality. The decision was declared immediately executory.