Lao v. Bumanglag
REITERATIONFacts
The Antecedents: Husing Lao, former mayor of Pangutaran, Sulu, filed verified complaints against Esteban T. Bumanglag, the municipal judge, for alleged irregularities, including non-observance of office hours and issuing blank search warrants. Procedural History: The complaints were indorsed for investigation. The respondent judge submitted sworn statements attesting to his daily attendance. The respondent judge alleged vindictiveness as the motive for the complaint, citing personal and political conflicts. During the investigation, an objection to the competency of a witness regarding police blotters was sustained, leading to a certiorari action by the complainant and a restraining order suspending the investigation. The Petition: The administrative case was filed against respondent Municipal Judge Esteban T. Bumanglag for alleged irregularities in the performance of his duties.
Issue(s)
Whether the administrative case against respondent judge should be dismissed for having become moot and academic. Whether the charges of irregularities against the respondent judge were substantiated.
Ruling
The administrative case is dismissed for having become moot and academic.
Ratio Decidendi
On Whether the administrative case against respondent judge should be dismissed for having become moot and academic: The Court held that the objective of the administrative charge was to remove the respondent from office. This objective was attained when the President of the Philippines accepted the resignation of Judge Bumanglag on November 24, 1972. Therefore, the case had become moot and academic. The Court noted that the investigating judge, Judge Abalos, retired on June 15, 1975, and his successor, Judge Jainal Rasul, recommended the dismissal of the case on the same grounds. The resolution explicitly states that as the objective of the administrative charge was to remove the respondent from office and since that objective was attained when the President accepted his resignation, this case is dismissed for having become moot and academic. On Whether the charges of irregularities against the respondent judge were substantiated: While not explicitly detailed in the main resolution, the concurring opinion of Justice Muñoz Palma highlights that no evidence was adduced to substantiate the charge. This suggests that even if the case had not become moot, the lack of evidence would have been a significant factor. The procedural history indicates that the investigation was suspended due to a certiorari action and a restraining order, potentially hindering the full presentation and evaluation of evidence.
Main Doctrine
An administrative case against a public official is dismissed as moot and academic when the objective of removing the official from office has been attained by the acceptance of his resignation.