Recario v. Aquino
REITERATIONFacts
The Antecedents: Complainants filed an administrative complaint against respondent District Judge Benjamin Aquino for alleged damage caused by his failure to immediately act on a case for prohibition (Case No. 13335). This prohibition case was filed to prevent the municipal judge of Muntinlupa from proceeding with an ejectment case (Civil Case No. 228) where the complainants were defendants. The complainants alleged that the judge's delay in acting on the prohibition case led to the demolition of their properties. Procedural History: The respondent judge admitted that the prohibition case was filed on June 4, 1970, and set for hearing on July 22, 1970. He stated that the ejectment case had already been decided by the municipal court, and the decision was appealed to the CFI, rendering the prohibition case moot. The respondents in the prohibition case moved for dismissal on the ground of appeal. The respondent judge asserted that the complainants did not seek a writ of preliminary injunction or restraining order to maintain the status quo. The respondent judge resigned from the service on September 30, 1972. The Petition: The administrative complaint was filed by Maria Esporlas Vda. de Recario, Florentino Gadaza, and Rosita Mitra against Judge Benjamin H. Aquino. The core of the complaint is the alleged failure of the respondent judge to act promptly on a prohibition case, which allegedly resulted in the demolition of the complainants' properties. The complainants contend that this inaction caused them damage.
Issue(s)
Whether the administrative complaint against the respondent judge should proceed despite his resignation from the service. Whether the respondent judge incurred delay in acting upon the prohibition case filed before his court.
Ruling
The Court dismissed the administrative complaint and considered the case closed and terminated. The Court found that the administrative case had become moot and academic due to the respondent judge's resignation from the service.
Ratio Decidendi
On Whether the administrative complaint against the respondent judge should proceed despite his resignation from the service: The Court resolved to dismiss the administrative complaint. It was noted that the respondent judge had resigned from the service on September 30, 1972. Given that the case, at its worst, could only result in the respondent's separation from the service, and he had already separated from the service by resignation, the administrative case was rendered moot and academic. Therefore, any further investigation would be a waste of time and effort. On Whether the respondent judge incurred delay in acting upon the prohibition case filed before his court: The Court found no indication of bad faith or undue delay on the part of the respondent judge. The respondent admitted the filing of the prohibition case and its setting for hearing on the merits 48 days after its filing. The respondent also correctly pointed out that the ejectment case had already been decided and appealed, rendering the prohibition case moot. Crucially, the complainants failed to seek a writ of preliminary injunction or a restraining order to maintain the status quo, which was their own error and not attributable to the respondent judge's actions or inactions. The facts as alleged in the respondent's answer were generally admitted as true in the complainants' reply.
Main Doctrine
An administrative complaint against a judge who has already resigned from the service becomes moot and academic, especially when the potential penalty would be separation from the service. The Court will not proceed with the investigation if the purpose of the case, which is to impose disciplinary sanctions, can no longer be achieved.