AM P 8; (May, 1979) (Digest)
A.M. No. P-8. May 31, 1979. Alfredo Brencis vs. Ely Fajardo.
FACTS
This is an administrative complaint filed by Alfredo Brencis against Deputy Sheriff Ely B. Fajardo. The complainant alleged that the respondent sheriff was guilty of dishonesty and misconduct. Specifically, it was charged that Fajardo collected the sum of P250.00 from Brencis. Furthermore, the respondent required Brencis to travel from Tigaon, Camarines Sur, to Manila personally to receive a Workmen’s Compensation Commission check worth P2,478.84, instead of simply mailing the check to the complainant’s address. This act allegedly imposed an unnecessary burden and expense on the complainant.
However, while this administrative matter was pending, a separate and prior disciplinary action had already been concluded against the same respondent sheriff. In an earlier case, Administrative Matter No. P-312, entitled “Lumen Policarpio v. Ely B. Fajardo,” the Supreme Court had already investigated and adjudicated charges against Fajardo concerning his conduct in another official capacity.
ISSUE
The primary issue is whether the present administrative complaint against Deputy Sheriff Ely B. Fajardo should proceed to a full investigation and resolution on its merits, given the developments in a separate, prior administrative case involving the same respondent.
RULING
The Supreme Court dismissed the administrative case against Ely B. Fajardo, declaring it moot and academic. The legal logic for this dismissal is rooted in judicial economy and the finality of a prior disciplinary action. The Court took judicial notice of its own prior resolution in A.M. No. P-312. In that case, the Court, through Justice Barredo, had already found respondent Fajardo guilty of gross misconduct and grave abuse of authority in his duties as a special sheriff. As a consequence of that finding, the Court in its August 3, 1977, Resolution ordered the immediate dismissal of Fajardo from the service with forfeiture of all benefits.
Since the respondent had already been dismissed from service in the earlier case, the objectives of administrative discipline—primarily to preserve the integrity of the judiciary and to mete out appropriate penalties—had already been fully served. Continuing with the instant case would serve no practical purpose, as the maximum penalty of dismissal had already been imposed. Therefore, any further proceedings on the allegations of dishonesty and misconduct by Brencis would be superfluous. The Court resolved to dismiss the case, as the respondent’s separation from service rendered the new complaint moot.