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Office of the Court Administrator vs.

Indar,
669 SCRA 24,
A.M. No. RTJ-10-2232
April 10, 2012

Facts:
Judge Indar is suspected to have issued an alarming number of decisions on annulment cases which were
submitted to the Local Civil Registrar for registration. Due to the alarming mass of decisions, the LCR
reported to the Office of the Court Administrator. Pursuant to the report, OCA conducted a judicial audit
where it was found that Judge Indar did issue these spurious annulment decisions. Thus, this
administrative complaint case filed by OCA against Judge Indar for gross misconduct and dishonesty.
Because there are also grounds for disbarment of lawyers, the court wishes to issue disciplinary actions
against the judge in the same proceeding.

Issue: Can the administrative case against Judge Indar also be considered as a disciplinary proceeding
against him as a member of the Bar.

Ruling:
Yes, the administrative case can also be considered as a disciplinary proceeding against Judge Indar as a
member of the Bar.

AM 02-9-02-SC provides that administrative cases against judges on grounds which are simultaneously
grounds for disciplinary action for members of the Bar shall also be treated as a disciplinary action against
the judge.

In this case, Judge Indar has been tried and found guilty for gross misconduct and dishonesty, which are
also grounds for disciplinary action for a lawyer. Thus, he can be given the proper disciplinary action for
such—disbarment—in the same administrative case, pursuant to AM 02-9-02-SC.