G.R. No. RTJ-02-1739; January 22, 2003
Liza Limliman, et al., complainants, vs. Judge Nelsonida T. Ulat-Marrero, respondent.

FACTS

Complainants, all court employees of the Regional Trial Court, Branch 10, La Trinidad, Benguet, filed an administrative complaint dated February 18, 2002, charging respondent Judge Nelsonida T. Ulat-Marrero with grave misconduct and conduct unbecoming of a judge. The allegations included delegating the drafting of decisions to a legal researcher, entertaining lawyers with pending cases in her chambers, participating in auction sale biddings, and mistreating court personnel. The respondent judge, in her comment, denied all accusations and welcomed a formal investigation to address what she termed as misconceptions.
The Office of the Court Administrator (OCA), in a memorandum dated October 27, 2002, recommended that the case be referred to an Associate Justice of the Court of Appeals for a formal investigation, report, and recommendation, as factual issues necessitated a full inquiry. However, on November 12, 2002, the OCA received a letter from the respondent judge’s husband, attaching a Certificate of Death showing that Judge Ulat-Marrero had died on October 3, 2002, due to respiratory failure.

ISSUE

Whether the administrative complaint against the respondent judge should proceed despite her death during the pendency of the case.

RULING

The Supreme Court dismissed the administrative complaint. The legal logic is anchored on fundamental due process and established jurisprudence regarding the effect of a respondent’s death pending administrative proceedings. The Court, citing precedents such as Baikong Akang Camsa vs. Judge Aurelio Rendon, emphasized that the right to be heard is a basic component of due process. To allow a formal investigation to continue against a respondent who can no longer defend herself would constitute a denial of this right.
The Court distinguished situations where an investigation had already been completed prior to death, which might allow for a resolution on the merits, from cases like the present one where no formal investigation had commenced. Here, the OCA itself had noted that factual issues remained unresolved, requiring the reception of evidence. With the respondent’s demise, such an inquiry became impossible without violating due process. Consequently, the case was deemed closed and terminated. The dismissal is without prejudice to any other appropriate actions concerning the respondent’s retirement benefits, but no administrative sanction could be imposed posthumously under these circumstances.