A.M. No. RTJ-15-2438, September 2, 2020
Sharon Flores-Concepcion, Complainant, v. Judge Liberty O. Castaneda, Regional Trial Court, Branch 67, Paniqui, Tarlac, Respondent. (Dissenting Opinion of Justice Caguioa)

FACTS

This administrative case stemmed from a complaint filed against Judge Liberty O. Castaneda for Gross Ignorance of the Law. The Office of the Court Administrator (OCA) directed the respondent to file her comment on the complaint-affidavit. The respondent, however, ignored multiple directives from the OCA issued from 2010 onwards, failing to submit any comment throughout the investigation which concluded in 2014. Her conduct constituted defiance of the lawful orders of the Court.
During the pendency of the proceedings before the Supreme Court, the respondent died. The majority of the Court dismissed the case on the ground of mootness, reasoning that the death of the respondent forecloses her right to due process and that the primary purpose of administrative penalties—dismissal from service—can no longer be served. Justice Caguioa dissented from this majority ruling.

ISSUE

Whether the death of the respondent during the pendency of an administrative case ipso facto warrants its dismissal.

RULING

No. The death of the respondent does not automatically necessitate the dismissal of the administrative case. The prevailing rule, as established in Limliman v. Ulat-Marrero, is that death does not lead to ipso facto dismissal, subject to recognized exceptions considering due process, exceptional humanitarian circumstances, and the kind of penalty. In this case, the respondent was not denied due process. The essence of administrative due process is notice and a real opportunity to be heard. Here, the respondent was given the requisite notice and opportunity through the OCA’s orders to comment. Her defiant failure to avail herself of this opportunity satisfied the due process requirement; her right was not violated but was waived.
Furthermore, the supervening death does not render the imposition of a penalty impossible. The Court retains discretion to declare administrative liability and impose appropriate sanctions, such as a fine payable by the estate or forfeiture of benefits, as seen in precedents like Gonzales v. Escalona. A declaration of liability, even posthumously, serves the paramount public interest of preserving judicial integrity and upholding public accountability. It ensures that entitlement to government benefits is contingent upon the proper discharge of duties. Therefore, the case should not be dismissed merely due to the respondent’s death. Justice Caguioa voted to find the respondent administratively liable for Gross Ignorance of the Law, but noted that, as she had already been dismissed from service with forfeiture of benefits in a prior case, no further penalty could be imposed.