Facts:

This administrative complaint was initiated by Antonio Abanil against Abel Francisco B. Ramos, Jr., who served as Sheriff IV at the Office of the Clerk of Court in the Regional Trial Court of Iriga City. The sequence of events began on August 3, 1995, when Abanil executed a promissory note for ₱79,000 in favor of Luis Oliva while at the house of Domingo Hosana, the Barangay Chairman of Santiago Young, Nabua, Camarines Sur. During this event, Ramos acted as a witness to the promissory note. Subsequently, in early 1996, a case was filed by Oliva against Abanil related to this settlement, leading to the issuance of a writ of execution by the Municipal Circuit Trial Court (MCTC) on July 5, 1996. Ramos, in compliance with this writ, proceeded to levy Abanil's jeepney for auction scheduled for August 5, 1996. In an effort to stop the auction, Abanil filed a petition for injunction with the Regional Trial Court, which led to a temporary restraining order against the auction, comman

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Facts:

Background of the Case

• Complainant Antonio Abanil filed an administrative complaint against respondent Abel Francisco B. Ramos, Jr., then Sheriff IV of the Office of the Clerk of Court, Regional Trial Court in Iriga City.
• The complaint charged respondent with grave misconduct, conduct prejudicial to the best interest of the service, and giving unwarranted benefits, advantage or preference in the discharge of official functions.

Execution of the Promissory Note and Related Events

• On August 3, 1995, while at the residence of Domingo Hosana (Barangay Chairman of Santiago Young, Nabua, Camarines Sur), complainant executed a promissory note to pay Luis Oliva ₱79,000.00 on November 30, 1995, as part of an amicable settlement with Oliva.
• Respondent signed as a witness to this execution despite his official position, raising questions about his impartiality given his relations with the involved parties.

Subsequent Legal Proceedings

• Early in 1996, Luis Oliva initiated an action before the Municipal Circuit Trial Court (MCTC) of Nabua-Bato, Camarines Sur (Barangay Case No. 1-96) against complainant regarding the settlement.
• A writ of execution was issued on July 5, 1996, leading respondent, in his capacity as sheriff, to levy on the complainant’s jeepney and schedule it for auction on August 5, 1996.
• The complainant reacted by filing a petition for injunction in Civil Case No. IR-2827 with the Regional Trial Court of Iriga City and a motion with the MCTC, both aimed at halting the auction sale.

Allegations of Misconduct

• On November 14, 1996, the Office of the Court Administrator (OCA) received the complaint alleging that during working hours on August 3, 1995, respondent, along with Oliva, Hosana, and two others, was involved in a drinking spree at Hosana’s residence.
• The complainant alleged that during the said drinking spree, respondent used threats and intimidation to compel him to sign the promissory note, and later, on August 7, 1996, respondent personally served copies of Oliva’s pleadings to the complainant’s counsel, thereby showing partiality and pursuing personal interest instead of acting impartially.

Respondent’s Defense

• Respondent admitted being at Hosana’s residence but contended he arrived after 5:00 PM, thus outside regular office hours, and maintained that his presence was at the request of Oliva.
• He asserted that upon learning the meeting was merely a barangay-level conciliation proceeding, he distanced himself from the conflict and signed as witness only at Hosana’s request.
• Furthermore, he argued that if he served the pleadings, it was a legitimate act within his official capacity as sheriff to enjoin the auction sale, not an act of personal interest or bias.

Findings by the Office of the Court Administrator

• The OCA found that the evidence failed to establish the respondent’s participation in a drinking spree during working hours or that he used threats to secure the complainant’s signature on the promissory note.
• However, the evidence indicated that by signing as a witness, respondent compromised his neutrality, especially since he was a party to the execution of the settlement agreement and was related as a ‘barriomate’ to relevant parties.
• The OCA concluded that even in the absence of clear evidence of personal gain, his conduct was prejudicial to the best interest of the service and recommended a suspension of one (1) month and one (1) day based on Section 22 of Rule XIV of the Omnibus Rules Implementing Book V of Executive Order No. 292.

Final Administrative Decision

• While the OCA’s findings regarding misconduct were supported by evidence, the ruling court disagreed with the short suspension recommendation.
• Under the Personnel Manual of the Supreme Court, conduct grossly prejudicial to the best interest of the service qualifies as a grave offense.
• The court determined that, for a first offense of this nature, the proper penalty is a suspension ranging from six (6) months and one (1) day to one (1) year.

Issue:

Whether respondent’s act of signing as a witness in the execution of the promissory note, despite his close connection to the parties involved, constitutes conduct prejudicial to the best interest of the service.

• Determining if his participation compromised the impartiality expected from a court officer.
• Assessment of whether his conduct, though lacking evidence of direct threat or personal gain, still undermined the integrity of official functions.

Whether the recommended penalty of one (1) month and one (1) day suspension by the OCA was adequate in view of the gravity of the misconduct committed.

• Examination of applicable administrative rules and the Personnel Manual’s classification of the offense.
• Consideration of the required standard of deference from court personnel to ensure judicial impartiality and integrity.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)