A.M. No. MTJ-06-1644 ; July 31, 2006
Angelina Sarmiento, et al., complainants, vs. Judge Yolanda M. Leonardo, Sheriff III Jess A. Arreola, and Sheriff III Apolinar S. Juan, respondents.

FACTS

Complainants, defendants in an ejectment case, filed an administrative complaint against respondents. They charged Judge Yolanda M. Leonardo of the Metropolitan Trial Court (MeTC) of Manila, Branch 10, with ignorance of the law and oppression for issuing a writ of demolition to enforce a 1993 ejectment judgment, despite the lapse of over five years from its finality and despite a separate expropriation case over the same property filed by the City of Manila. They further charged Sheriffs Jess A. Arreola (MeTC, Branch 10) and Apolinar S. Juan (MeTC, Branch 17) with grave misconduct, coercion, and usurpation of authority for enforcing the writ and allegedly coercing complainants to demolish their own houses.
Respondents denied any impropriety. Judge Leonardo asserted that the five-year period for execution by motion under Rule 39 was interrupted by delays not attributable to the prevailing party, including a fire that destroyed the records and the complainants’ own dilatory motions. She maintained issuing the writ was a ministerial duty after the denial of complainants’ motion to quash. Sheriff Arreola denied coercion, explaining he merely asked directions from Sheriff Juan, who was familiar with the area, and sought barangay assistance due to hostility. Sheriff Juan denied active participation, stating he only provided directions when chanced upon.

ISSUE

Whether respondents are administratively liable for the acts complained of.

RULING

The Supreme Court dismissed the complaint for lack of merit. In administrative proceedings, the burden of proof lies with the complainant to establish the charges by substantial evidence. Here, complainants failed to discharge this burden. The Court upheld the presumption of regularity in the performance of official duties by the judge and the sheriffs in the absence of convincing proof to the contrary.
Regarding Judge Leonardo, the issuance of the writ of demolition was a judicial function. The Court found no evidence of bad faith, malice, or corrupt motive. Her reliance on the principle that delays not caused by the prevailing party interrupt the five-year execution period was a proper exercise of judicial discretion. An error in judgment, if any, is not correctable in an administrative proceeding absent proof of fraud or dishonesty.
Concerning the sheriffs, the evidence showed they acted within their authority. Sheriff Arreola’s act of seeking directions and barangay assistance was reasonable for the peaceful execution of the writ. There was no proof that Sheriff Juan actively participated in the demolition or coerced the complainants; his limited assistance did not constitute usurpation of authority. The Court emphasized that while it will not tolerate misconduct, it will also protect court personnel from unfounded accusations that disrupt the administration of justice.