Licudine v. Saquilayan
REITERATIONFacts
The Antecedents: Erlinda Y. Licudine (complainant) was the defendant in a civil case for damages. The trial court rendered a decision ordering her and another defendant to pay plaintiff Prudencio Dolon P261,363.41. After the decision became final, a writ of execution was issued. Sheriff Wilmar M. De Villa levied upon complainant's car and scheduled it for auction. Complainant alleged that she and Dolon agreed to a compromise of P120,000.00 payable in installments, an agreement allegedly made in the presence of respondents Atty. Wilfredo P. Saquilayan (Branch Clerk of Court) and Sheriff De Villa. Complainant paid P50,000.00, acknowledged by Dolon, and executed a promissory note for the remaining P70,000.00, which she paid on January 30, 1998. Despite these payments, Sheriff De Villa issued a Sheriff's Return stating the writ was "Partially Satisfied." Subsequently, Sheriff De Villa levied upon complainant's van and sold it for P60,000.00 to Dolon. Complainant protested and was told to redeem the van for P60,000.00, but Sheriff De Villa refused to accept the amount. Complainant further alleged that respondents misrepresented that her P120,000.00 payment would be full satisfaction and that Atty. Saquilayan received P2,000.00 as professional fee for arranging the compromise. Procedural History: Complainant filed a verified letter-complaint against Atty. Saquilayan and Sheriff De Villa with the Office of the Court Administrator (OCA) for dishonesty and misconduct. Subsequently, complainant, assisted by counsel, sent a letter to the OCA requesting the withdrawal of her complaint "for personal reasons." The OCA required the respondents to file their comment. Respondents filed their separate comments, averring that the allegations were untrue and resulted from a misunderstanding. The OCA, through Deputy Court Administrator Jose P. Perez, recommended that the complaint be dismissed but that the respondents be advised to be more circumspect. The Supreme Court ordered the case to be re-docketed as a regular administrative matter and required parties to manifest if they were submitting it for resolution based on existing pleadings. Only respondents submitted a manifestation. The Supreme Court noted the complainant's withdrawal of the complaint. The Petition: This case originated from an administrative complaint filed by Erlinda Y. Licudine against Branch Clerk of Court Wilfredo P. Saquilayan and Sheriff Wilmar M. De Villa for dishonesty and misconduct related to the execution of a judgment. The core of the complaint was the alleged misrepresentation by the respondents regarding a compromise agreement and the subsequent actions taken during the execution, including the sale of the complainant's property. The complainant later sought to withdraw her complaint. The Supreme Court was tasked with determining whether the respondents committed dishonesty and misconduct, and whether the withdrawal of the complaint should lead to its dismissal.
Issue(s)
Whether the respondents committed dishonesty and misconduct in relation to the execution of judgment in Civil Case No. 1470-97. Whether the complainant's withdrawal of her complaint warrants the dismissal of the administrative case.
Ruling
The administrative complaint against Branch Clerk of Court Wilfredo P. Saquilayan and Sheriff Wilmar M. De Villa was DISMISSED. The Court found the record bereft of any evidence showing that the respondents benefited materially from the transactions. While acknowledging the impropriety of court employees initiating amicable settlements, the Court found no positive proof that the respondents initiated the settlement or that Atty. Saquilayan received any professional fee. Given the complainant's withdrawal and the lack of substantial evidence, the charges remained unsubstantiated.
Ratio Decidendi
On Issue 1: The Supreme Court found the evidence on record to be bereft of any showing that the respondents materially benefited from the transactions complained about. While it is improper for court employees to initiate an amicable settlement of a money judgment, especially when it undermines the integrity of the court, the complainant's withdrawal of her complaint meant that the allegations, including the specific claim that Atty. Saquilayan demanded and received P2,000.00 as a professional fee, were not substantiated by substantial evidence. In administrative proceedings, the complainant bears the burden of proving their allegations, and in the absence of contrary evidence, the presumption of regularity in the performance of official duties prevails. On Issue 2: The Supreme Court reiterated the settled rule that a complainant's withdrawal of their complaint or desistance from pursuing it does not necessarily warrant the dismissal of an administrative case. The Court's disciplinary power is not dependent on the will or pleasure of the complainant. However, the Court also noted that there are instances where an administrative case cannot proceed without the active cooperation of the complainant, and in such situations, dismissal may be the only alternative. In this case, the complainant's withdrawal left the charges against the respondents unsubstantiated, and since there was no substantial evidence to prove the allegations of dishonesty and misconduct, the Court dismissed the complaint.
Main Doctrine
The Supreme Court retains jurisdiction over administrative cases involving court personnel even if the complainant withdraws their complaint. However, the dismissal of such a case may be warranted if the withdrawal results in the charges remaining unsubstantiated, as the complainant bears the burden of proving their allegations by substantial evidence. The Court emphasized that the conduct of court personnel must be beyond reproach and free from suspicion.