RE: CONVICTION OF MUNICIPAL CIRCUIT JUDGE AMANDITO D. ARANETA BY THE SANDI­GANBAYAN IN CRIMINAL CASE NO. 7220

Araneta

The Case

This is an administrative proceeding brought by the Supreme Court itself against Municipal Circuit Judge Amandito D. Araneta, after the Sandiganbayan convicted him beyond reasonable doubt of the crime of infidelity in the custody of prisoners. The Court treats the criminal conviction as the springboard for administrative liability, and the case matters because it shows how a final conviction for a crime involving the abuse of judicial office can by itself justify the ultimate administrative penalty of dismissal, even without a full re-examination of the underlying facts.

Procedural History

The Second Division of the Sandiganbayan, in a criminal case entitled People of the Philippines versus Judge Amandito D. Araneta, found the respondent guilty beyond reasonable doubt of infidelity in the custody of prisoners. He was sentenced to an indeterminate penalty ranging from three months and one day of arresto mayor as minimum to one year, eight months and one day of prision correccional as maximum, to temporary special disqualification from six years and one day to eight years, and to pay the costs. The Sandiganbayan had earlier suspended him from office pending litigation as of July 1, 1983, and after conviction placed him under probation.

On June 6, 1984, the Ministry of Justice referred a copy of that decision to the Supreme Court. In a resolution dated July 10, 1984, the Court directed the Office of the Court Administrator to file an administrative case against the respondent. On July 19, 1984, he was administratively charged with neglect of duty and conduct prejudicial to the best interest of the service and was directed to file an answer or explanation, which he never submitted. A separate administrative matter arose from a resolution of the Peace and Order Council of Norala, South Cotabato, asking for his immediate relief or dismissal. The Court resolved the matter as an original administrative action of its own.

Facts

The criminal conviction rested on a course of conduct spanning about five months. The respondent judge asked that detention prisoners be assigned to him to perform domestic chores and carpentry work in a store he owned beside his house. Those prisoners were never under guard. They went back and forth between his house and the jail, which was about 500 meters away, and the logbook of the Norala Police Station showed that their custody had been transferred to him.

On December 1, 1979, after the work at his place was finished, he ordered three detention prisoners to return to the jail by themselves. One of the three escaped. Serious charges for murder and double frustrated murder were still pending preliminary investigation before the respondent judge's own sala against that prisoner.

Separately, the Peace and Order Council of Norala alleged that he had dismissed a criminal case for malicious mischief without arraignment, trial, or hearing; that he had refused to act on a criminal complaint involving the death of a police officer, saying he planned to go on leave, and then required a 45,000 peso bail bond for the release of an accused who was an escapee; and that he was seldom in his office. The Court found it unnecessary to delve into these reasons.

Issues

• Whether or not a judge's conviction by the Sandiganbayan for infidelity in the custody of prisoners, arising from his misuse of the powers of his office, constitutes conduct prejudicial to the best interest of the service and renders him unfit to continue in office.
• Whether or not the respondent may be dismissed from the service on the basis of that conviction even without a separate inquiry into the other grounds alleged against him.

Applicable Provisions

The decision does not quote any statutory text; it rests on the Court's administrative power over judges and on the crime of infidelity in the custody of prisoners as found by the Sandiganbayan. The controlling principle is that a conviction for a crime involving abuse of judicial office is itself a ground for administrative discipline.

Ruling

On the first issue, the Court held that the respondent's conduct was highly prejudicial to the service, gravely inimical to the interest of justice, and rendered him miserably unfit for continuance in office. He had misused and abused the powers of his office by taking detention prisoners into his personal service without guard, and by sending them back to jail unescorted, allowing a prisoner facing serious charges to escape.

On the second issue, the Court held that the prayer for his immediate relief could and should be granted without need for delving into the reasons advanced in the separate administrative matter. The conviction beyond reasonable doubt supplied a sufficient and independent basis for dismissal.

Doctrine

A judge who uses detention prisoners for his personal benefit and allows them to move about without guard commits a grave abuse of judicial office. A conviction beyond reasonable doubt for such a crime is conduct prejudicial to the best interest of the service and warrants dismissal, with forfeiture of retirement benefits and pay, and with prejudice to reinstatement in any branch of government. The administrative penalty may rest on the conviction alone, without a separate inquiry into other alleged grounds.

Disposition

The Court ordered Judge Amandito D. Araneta dismissed from the service, with forfeiture of all retirement benefits and pay and with prejudice to reinstatement in any branch of the government or any of its agencies or instrumentalities, the decision being immediately executory.

Remember This

Memorize this line: a conviction for a crime involving abuse of judicial office is itself conduct prejudicial to the best interest of the service and justifies dismissal. Examiners use this case to test the administrative consequences of a criminal conviction of a judge and the rule that dismissal may rest on the conviction alone.