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1- Flores vs. Judge Castaneda Case Digest

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80 views1 page

1- Flores vs. Judge Castaneda Case Digest

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Flores-Concepcion vs.

Judge Castaneda

FACTS:
Petitioner Concepcion filed an administrative complaint against respondent Judge Castaneda. She
claimed that she received a copy of a Decision in a civil case decided by Judge Castaneda declaring her
marriage against Vergel Concepcion void ab initio even though she did not know that her husband filed a
petition and she never participated in the case. In fact, when she went to the court, she discovered that no
hearing was conducted at all.

During the pendency of the administrative case, however, Judge Castaneda died.

ISSUE:
Whether or not the death of respondent Judge Liberty O. Castaneda warrants the dismissal of the
Administrative Complaint lodged against her.

RULING:
YES. Prudence dictates that this case should be rendered moot as respondent Judge Castaneda died.
She could no longer be in a position to defend herself from these charges in a motion for
reconsideration. She could no longer admit to the charges, express remorse, or beg for clemency.
Proceeding any further would be a gross violation of her constitutionally guaranteed right to due
process.

Administrative proceedings require that the respondent be informed of the charges and be given an
opportunity to refute them. Even after judgment is rendered, due process requires that the respondent not
only be informed of the judgment but also be given the opportunity to seek reconsideration of that
judgment. This is the true definition of the opportunity to be heard.

Dead respondents have no other recourse. They will never know how the proceedings will continue, let
alone submit responsive pleadings. They cannot plead innocence or beg clemency. Death forecloses any
opportunity to be heard. To continue with the proceedings is a violation of the right to due process.

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