AM RTJ 10 2235; (March, 2013) (Digest)
G.R. No.: A.M. No. RTJ-10-2235; March 11, 2013 (Formerly A.M. No. 10-3-94-RTC)
Case Title: OFFICE OF THE COURT ADMINISTRATOR, Complainant, vs. JESUS L. GRAGEDA, Respondent.
FACTS
1. Judge Jesus L. Grageda compulsorily retired on November 25, 2009.
2. The Office of the Court Administrator (OCA) conducted a judicial audit at his court, the Regional Trial Court, Branch 4, Panabo City, from November 17 to 26, 2009.
3. The OCA submitted its audit report on March 24, 2010, which was re-docketed as a regular administrative matter by the Court’s First Division on April 28, 2010.
4. The April 28, 2010 Resolution directed Judge Grageda to explain various administrative charges, including: gross inefficiency and undue delay in deciding/resolving numerous civil and criminal cases; gross ignorance of procedural law; gross misconduct for unreasonable delay in resolving motions for reconsideration; and dishonesty for false certifications in his Certificates of Service. He was also directed to explain why he should not be held liable for rendering decisions/orders beyond his last working day (November 24, 2009).
5. The same Resolution directed court personnel (Ms. Belen V. Basa, Mr. Boyd James B. Bacaltos, Ms. Arlene C. Sison, and Ms. Marianne G. Baylon) to explain or comply with certain directives and ordered the retention of ₱200,000 from Judge Grageda’s retirement benefits.
6. In his explanation, Judge Grageda admitted some delays but cited heavy caseload, lack of personnel, and inadequate facilities as reasons. He denied dishonesty, claiming reliance on his staff’s assurances. He argued his last working day was his retirement day (November 25, 2009). He pleaded for leniency.
7. The OCA, in its October 8, 2012 report, recommended finding Judge Grageda guilty of Gross Ignorance of the Law (for acting on his retirement day) and Gross Inefficiency, and imposing a ₱200,000 fine from his withheld benefits. It also recommended accepting the compliance of the court staff with a stern warning.
ISSUE
Whether the Supreme Court has jurisdiction to pursue the administrative complaint and impose administrative liability on Judge Jesus L. Grageda, considering he had already compulsorily retired from the judiciary before the complaint was formally instituted.
RULING
The Supreme Court DISMISSED the administrative complaint against retired Judge Jesus L. Grageda for lack of jurisdiction.
1. Legal Principle on Jurisdiction: Jurisprudence holds that for the Court to acquire jurisdiction over an administrative proceeding, the complaint must be filed during the respondent’s incumbency. Administrative jurisdiction is predicated on the respondent holding a government office. However, once jurisdiction attaches at the time of filing, it is not lost by the respondent’s subsequent separation from service (e.g., resignation, retirement, death).
2. Application to the Case: Judge Grageda retired on November 25, 2009. The judicial audit was completed and the OCA report was submitted on March 24, 2010. The case was re-docketed as a regular administrative matter by the Court on April 28, 2010. Therefore, the administrative proceeding was formally instituted months after his retirement.
3. Consequence: His retirement effectively barred the Court from pursuing the administrative case that was instituted after his tenure. It divested the Court (and the OCA) of jurisdiction to subject him to administrative sanctions. The Court cited precedents (Office of the Ombudsman v. Andutan, Jr.; OCA v. Villanueva; and a prior related matter involving Judge Grageda himself, Re: Missing Exhibits and Court Properties in RTC, Branch 4, Panabo City) where administrative cases were dismissed because they were initiated after the respondent’s separation from service.
4. Disposition:
The complaint against Judge Grageda was dismissed.
The Fiscal Management Office, OCA, was directed to immediately release the ₱200,000 withheld from his retirement benefits, unless retained for another lawful reason.
* The explanations/compliance of the court staff (Bacaltos, Basa, Sison, Baylon) were accepted with a STERN WARNING that repetition would be dealt with more severely.