Liguid v. Camano, Jr.
REITERATIONFacts
The Antecedents: Complainant Asuncion S. Liquido and respondent Judge Policarpio S. Camano, Jr. engaged in a romantic relationship and cohabited as husband and wife from 1976 until 1996, during which time they had a child, Joanne. Complainant alleged that respondent, a married man, promised to marry her and support their child, but failed to do so. She further accused him of abandonment of office, dishonesty, oppression, deceit, immorality, and misconduct, including alleged illicit relations with other women and physical abuse towards her. Respondent denied these allegations, asserting that complainant was aware of his existing marriage and that he provided support for their daughter. He claimed to have maintained a good reputation and fulfilled his judicial duties diligently. Procedural History: Complainant filed an administrative complaint against Judge Camano on November 7, 1997, detailing various charges. The case was docketed as A.M. No. RTJ-99-1509. During the pendency of the proceedings, respondent judge applied for and was granted optional retirement, effective May 31, 1998. The Court initially withheld his retirement benefits pending resolution of administrative complaints. Subsequently, on November 17, 1999, a portion of his benefits was released, with P50,000.00 withheld pending the resolution of the administrative cases. The Court resolved to docket the case as a regular administrative proceeding and required the parties to manifest their willingness to submit the case for resolution based on the existing pleadings. The Petition: The complainant initiated this administrative proceeding by filing a complaint against Judge Policarpio S. Camano, Jr. for abandonment, dishonesty, oppression, deceit, immorality, and misconduct in office. She sought administrative liability for the respondent and an order for him to provide regular support for their child, Joanne. The core of her petition was that the respondent, despite their long-term cohabitation and the birth of their child, reneged on promises of marriage and support, engaged in abusive behavior, and maintained illicit relationships. The respondent, in his defense, denied the allegations, attributing the complaint to the complainant's desperation and asserting his adherence to judicial and personal integrity. The case was submitted for resolution based on the pleadings filed, as further testimony was deemed unnecessary and would unduly prolong the proceedings.
Issue(s)
Whether respondent judge committed serious misconduct and violated the Code of Judicial Conduct. Whether there was sufficient evidence to support the charge of immorality against respondent judge. Whether respondent judge's optional retirement from service renders the administrative complaint moot and academic. Whether respondent judge should be ordered to provide support for his daughter, Joanne L. Camano.
Ruling
The Court found respondent Judge Policarpio S. Camano, Jr. GUILTY of Serious Misconduct and Violation of the Code of Judicial Conduct. He was imposed a FINE of Twenty Thousand Pesos (₱20,000.00).
Ratio Decidendi
On the charge of Serious Misconduct and Violation of the Code of Judicial Conduct: The Court found overwhelming documentary proof of respondent judge's perfidy, including pictures, letters, and affidavits. These documents, along with sworn statements from the then Cavite City Mayor and the Register of Deeds of Cavite City, established that respondent and complainant cohabited and held themselves out as husband and wife for over twenty years, from 1976 to July 14, 1996. This belied respondent's claim that he distanced himself from complainant upon his appointment to the judiciary in 1983. The Court emphasized that judges are required to observe exacting standards of morality and decency, and their private conduct must be free from the appearance of impropriety. Respondent's behavior of living openly and scandalously with a woman not his wife and siring a child by her constituted gross and serious misconduct, which would have warranted dismissal had he not optionally retired. On the sufficiency of evidence for immorality: The Court took exception to the OCA's finding of insufficient evidence for immorality, stating that substantial evidence, which is relevant evidence a reasonable mind accepts as adequate to justify a conclusion, was present. The Court found overwhelming documentary proof of respondent's perfidy, which, in administrative proceedings where affidavits can substitute for direct testimony, assumes decisive weight. The sworn statements from prominent individuals in Cavite City, attesting to the long-term cohabitation of respondent and complainant as husband and wife, provided substantial evidence of respondent's immoral conduct. On the effect of retirement: The Court reiterated that cessation from office due to retirement does not warrant the dismissal of an administrative complaint filed against a public official while still in service, nor does it render the case moot and academic. The jurisdiction of the Court at the time of filing is not lost by the respondent's subsequent retirement. Judges are still answerable for administrative liability even after retirement, and their retirement benefits can be withheld pending resolution of such cases. On the order for support: While the OCA recommended ordering respondent to support his daughter, the Court's final resolution focused on the fine for misconduct. The specific directive for support was not explicitly detailed in the dispositive portion of the Resolution, but the OCA's recommendation implies the Court considered the need for support, even if the primary penalty imposed was a fine for misconduct.
Main Doctrine
A judge's optional retirement from service does not preclude the Court from wielding its disciplinary authority and penalizing the respondent for his deplorable conduct as an erstwhile member of the bench, nor does it allow him to escape administrative liability as a member of the Bar.