SC applies by analogy double jeopardy in admin case

De Vera v. Layague (A.M. No. RTJ-93-986; September 26, 2000). Hence, respondent judge should no longer be punished a second time for exactly the same infraction. While double jeopardy does not lie in administrative cases, it would be contrary to equity and substantial justice to penalize respondent judge a second time for an act which he had already answered for.

xxx

WHEREFORE, respondent Judge William Layague is FINED in the amount of TEN THOUSAND PESOS (P10,000.00) for delay in the decision of Civil Case No. 19,794 and in the resolution of the incidents in Civil Case No. 17,215, Criminal Case No. 20,612-90 and Criminal Case No. 21,882-90. The complaints against him, of delay in deciding Civil Case No. 18,636-87 and for hastily granting bail in Criminal Case No. 24,413-91, are DISMISSED.