G.R. No. A.M. No. RTJ-08-2151. March 11, 2014.
OFFICE OF THE COURT ADMINISTRATOR, Petitioner, vs. JUDGE EDWIN C. LARIDA, JR., RTC, Branch 18, Tagaytay City, Respondent.

FACTS

A fire occurred on October 12, 2008, at the records room of RTC Branch 18 in Tagaytay City, suspected to be arson. The Office of the Court Administrator (OCA) formed an investigative team, which uncovered alleged anomalies by Presiding Judge Edwin G. Larida, Jr.: (1) violating Administrative Circular No. 28-2008 by detailing locally-funded employees without Supreme Court permission and allowing them to handle court records and draft orders; (2) allowing detailed employees to demand commissions from bonding companies; (3) extorting money from a detained accused; (4) defying a Supreme Court directive to stop hearing cases; (5) improperly granting bail in a drug case; (6) granting a motion to quash without a case record or prosecutor’s comment; and (7) granting a petition for duplicate titles under questionable circumstances. The Supreme Court referred the administrative complaint to the Court of Appeals for investigation. A separate letter-complaint by detailed employee Jayson Marticio, alleging irregularities by court staff, was consolidated but later dismissed due to Marticio’s failure to appear. The Investigating Justice recommended penalties for some charges and dismissal of others due to lack of substantial evidence.

ISSUE

Whether Judge Edwin C. Larida, Jr. is administratively liable for the alleged anomalies and irregularities.

RULING

The Supreme Court partly adopted the findings and recommendations of the Investigating Justice. Judge Larida was found liable for:
1. Violation of Administrative Circular No. 28-2008: He failed to submit the required inventory of locally-funded employees and allowed them to draft orders and handle confidential records, constituting violation of Supreme Court rules—a less serious charge under the Rules of Court. He was FINED ₱20,000.
2. Failure to Supervise Subordinates Diligently: He neglected to prevent detailed employees from engaging in misconduct, warranting a REPRIMAND with a warning.
3. Granting a Motion to Quash Without Prosecutor’s Comment: This constituted undue haste and violation of procedural rules, resulting in a FINE of ₱5,000.
The Court dismissed other charges (extortion, defiance of directive, improper bail, bribery, questionable land title issuance, and involvement in the fire) for lack of substantial evidence. The administrative complaint was resolved with modified penalties based on the gravity of the proven infractions.