G.R. No. A.M. No. P-2624. January 30, 1982.
THE COURT ADMINISTRATOR, complainant, vs. RAMON D. SANGALANG, respondent.

FACTS

Respondent Ramon D. Sangalang was a Clerk III designated as vault-in-charge in the Court of First Instance of Bataan, responsible for the custody of court records and exhibits. The Sandiganbayan charged him with malversation of public property under Article 217 of the Revised Penal Code. The information alleged that in September 1980, he willfully took, misappropriated, and embezzled several firearms from the court’s exhibits, with a total value of P3,600.00.
Upon arraignment, respondent pleaded guilty. The Sandiganbayan, appreciating the mitigating circumstances of voluntary surrender and plea of guilty, rendered a decision on October 13, 1981, finding him guilty and imposing an indeterminate penalty. The decision, which included perpetual special disqualification and an order to return the properties or indemnify the court, became final and executory on October 28, 1981. Following this final conviction, the Office of the Court Administrator filed the present administrative complaint for dishonesty, serious misconduct, and conduct prejudicial to the service.

ISSUE

Whether the respondent should be administratively disciplined based on his final criminal conviction for malversation of public property.

RULING

Yes. The Supreme Court ordered respondent’s separation from the service. The legal logic is straightforward: a final criminal conviction for an offense involving moral turpitude, such as malversation committed by a court employee in a position of trust, constitutes conclusive evidence of administrative guilt for charges like dishonesty and serious misconduct. The Court dispensed with a formal administrative investigation, citing precedents where the records of the criminal case provided a sufficient basis for determining administrative liability, especially after respondent waived his right to answer.
The ruling emphasizes that the criminal penalty of perpetual special disqualification imposed under Article 31 of the Revised Penal Code has an automatic administrative effect. This penalty perpetually deprives the convict of the public office held and disqualifies them from any future public employment. Consequently, respondent was deemed separated from the service as of the date his criminal conviction became final and executory. The Court thus declared his separation effective October 28, 1981, with forfeiture of retirement benefits and prejudice to reinstatement in any government agency.