A PUBLIC OFFICIAL’S RESIGNATION DOES NOT RENDER MOOT AN ADMINISTRATIVE CASE THAT WAS FILED PRIOR TO THE OFFICIAL’S RESIGNATION

:  To recall, the Supreme Court has held in the past that a public official’s resignation does not render moot an administrative case that was filed prior to the official’s resignation. In Pagano v. Nazarro, Jr., G.R. No. 149072, September 21, 2007, 533 SCRA 622, 628, the Supreme Court  held that:

In Office of the Court Administrator v. Juan [A.M. No. P-03-1726, 22 July 2004, 434 SCRA 654, 658], this Court categorically ruled that the precipitate resignation of a government employee charged with an offense punishable by dismissal from the service does not render moot the administrative case against him.  Resignation is not a way out to evade administrative liability when facing administrative sanction.  The resignation of a public servant does not preclude the finding of any administrative liability to which he or she shall still be answerable (Baquerfo v. Sanchez, A.M. No. P-05-1974, 6 April 2005, 455 SCRA 13, 19-20 cited in Office of the Ombudsman vs. Uldarico P. Andutan, Jr., G.R. No. 16467, July 27, 2011, BRION, J.).