AM RTJ 17 2486 Leonen (Digest)
A.M. No. RTJ-17-2486, September 8, 2020
RE: INVESTIGATION REPORT ON THE ALLEGED EXTORTION ACTIVITIES OF PRESIDING JUDGE GODOFREDO B. ABUL, JR., BRANCH 4, REGIONAL TRIAL COURT, BUTUAN CITY, AGUSAN DEL NORTE
FACTS
This administrative case stemmed from a complaint alleging that Presiding Judge Godofredo B. Abul, Jr. demanded money from detainees in exchange for favorable action on their cases. A judicial audit team confirmed the allegations. While the case was pending, Judge Abul was killed on August 5, 2017. The Office of the Court Administrator found him guilty of grave misconduct and, in view of his death, recommended a fine of P500,000.00 to be deducted from his retirement gratuity. In a September 3, 2019 Decision, the Court instead ordered the forfeiture of all his benefits. Judge Abul’s widow filed a Motion for Reconsideration, arguing the case was rendered moot by his death.
ISSUE
Whether the death of a respondent judge during the pendency of an administrative case, prior to final judgment, warrants the dismissal of the case.
RULING
Yes. The Court, through the ponencia of Associate Justice Ramon Paul L. Hernando and concurred with by Justice Leonen, granted the Motion for Reconsideration and dismissed the administrative case. The ruling is anchored on the fundamental right to due process. While the Court’s disciplinary jurisdiction is not automatically lost by a respondent’s cessation from office, death is a distinct and involuntary event that extinguishes administrative liability. The rationale is that due process requires a respondent be given the opportunity to be heard at all stages, including the right to appeal an adverse decision. Since Judge Abul died before final judgment, he was forever deprived of this opportunity to challenge the findings against him. Proceeding would violate his constitutional right.
Furthermore, imposing a monetary penalty or forfeiture of benefits would unjustly punish his innocent heirs. The Court distinguished death from resignation or retirement, which are voluntary acts and do not preclude the continuation of proceedings to preserve judicial integrity. Here, the purpose of administrative discipline—to preserve public confidence and reform the errant official—can no longer be served. The respondent can no longer betray public trust or be a stain on the judiciary. Therefore, the death of Judge Abul prior to finality of the case rendered it moot and necessitated its dismissal.