G.R. No. RTJ-15-2438, September 2, 2020
SHARON FLORES-CONCEPCION, COMPLAINANT, V. JUDGE LIBERTY O. CASTANEDA, REGIONAL TRIAL COURT, BRANCH 67, PANIQUI, TARLAC, RESPONDENT.

FACTS

This administrative case stemmed from a complaint filed against Judge Liberty O. Castañeda for Gross Ignorance of the Law in relation to her handling of a petition for declaration of nullity of marriage. The Office of the Court Administrator (OCA) found merit in the complaint, noting that the judge willfully disregarded procedural laws by, among others, not furnishing copies to necessary parties, relying on a psychologist’s report without the psychologist’s testimony, and deciding the case with undue haste. The OCA recommended a penalty of dismissal from service. However, during the pendency of the case before the Supreme Court, Judge Castañeda passed away.

ISSUE

The primary issue is whether the supervening death of the respondent judge renders the administrative case moot and necessitates its dismissal, thereby precluding a finding of administrative liability.

RULING

In her dissenting opinion, Justice Perlas-Bernabe argues that the administrative case should not be automatically dismissed due to the respondent’s death. The dissent emphasizes that the consequences of administrative misconduct have a persisting effect on the integrity of public service. Jurisdiction was already acquired, and the respondent was given multiple opportunities to be heard but failed to file any responsive pleading. Therefore, procedural due process was satisfied, as its essence in administrative proceedings is the opportunity to explain one’s side, which was afforded at the onset.
The dissent rejects the ponencia’s view that due process requires an opportunity to be heard at every single stage, including filing a motion for reconsideration. It clarifies that initial defects in due process may be cured by a motion for reconsideration on the merits, but the converse—that the inability to file such a motion due to death constitutes a due process violation—is not tenable. Furthermore, the dissent distinguishes administrative cases from criminal cases. The dismissal of criminal cases upon an accused’s death is grounded on the constitutional presumption of innocence, which does not apply to administrative proceedings. The purpose of administrative cases is to exact public accountability, not to impose penalties affecting life or liberty. Thus, while the penalty of a fine may no longer be imposed posthumously, a finding of liability, if established by the record, should be pronounced to remain on public record as a deterrent and to memorialize the affront to public service.