G.R. No. L-12487 - Custodio vs. Cristobal

The administrative matters originated from a writ of execution issued in Civil Case No. 59264, “Fruehauf Electronics Philippines, Inc. v. Signetics Corp., U.S.A.” by then Judge Alex L. Quiroz of Branch 156, RTC, Pasig City.
The trial court had rendered a decision in favor of Fruehauf Electronics, Inc. on October 31, 1996, which was later affirmed by the Court of Appeals.
Fruehauf, on May 21, 2001, filed a motion for the execution of the decision against Philips Semiconductors Philippines, Inc. (PSPI), a local subsidiary of the defendant, Signetics Corp., U.S.A.

By the Order dated January 21, 2002, Judge Quiroz ruled that execution could not be directed against PSPI because PSPI was not a party to the original case.
Fruehauf assailed the ruling before the Court of Appeals through certiorari and mandamus proceedings.
On September 10, 2003, the Court of Appeals set aside Judge Quiroz’s Order and directed him to issue a writ of execution against PSPI in accordance with the trial court’s decision.
Complying with the appellate court’s decision, on October 9, 2003, Judge Quiroz ordered the issuance of a writ of execution and specifically designated Deputy Sheriff Edwin V. Garrobo to implement it, assisted by Sheriff Mario Pangilinan.

With the authority of the Branch Clerk of Court, Respondent Sheriffs Garrobo and Pangilinan proceeded to Cabuyao, Laguna, to enforce the writ.
Although Judge Quiroz was on sick leave at the time, complainants—Atty. Nelson T. Antolin and Atty. Diosdado E. Trillana—objected upon arrival, asserting that:

The appellate court’s decision from September 10, 2003, had not become final and executory.
The writ of execution had been issued motu proprio without a requisite motion filed by the party, contrary to procedural rules.
The Order lacked an entry of judgment, as required by Rule 39, Sec. 1.

Despite these objections and the presentation of a copy of their motion to set aside the Order, the respondent sheriffs implemented the writ.
The complainants subsequently filed a letter-complaint on November 3, 2003, addressed to the Chief Justice regarding the issuance and implementation of the writ.

The complainants contended that Judge Quiroz’s issuance of the writ was erroneous on the following grounds:

The CA Decision permitting execution was not yet final and executory.
The writ was issued without a formal motion by the sustained party.
There was non-compliance with the requirement for an entry of judgment as stipulated in the Rules of Court.

A separate administrative complaint arose from Sheriff Garrobo’s claim of receiving unwarranted beratement and threats from Judge Quiroz upon his return from sick leave on November 27, 2003.

Sheriff Garrobo alleged that during a staff meeting, Judge Quiroz publicly berated and threatened him for executing the writ.
Judge Quiroz countered that his instructions were given in the context of ensuring proper execution of the writ and that any derogatory conduct attributed to him was unmerited.

Both the complaints concerning Judge Quiroz and the respondent sheriffs were subjected to evaluation by the Office of the Court Administrator (OCA).

On November 25, 2003, the Court required both Judge Quiroz and the respondent sheriffs to submit comments on the matter.

Judge Quiroz defended his issuance of the writ as being in compliance with the Court of Appeals’ directive.
Respondent Sheriff Garrobo contended that sheriffs have no discretion to delay the implementation of a writ, emphasizing its ministerial nature.
Sheriff Pangilinan maintained that his role was purely assisting and that he did not participate in the pre-implementation deliberations.

Dismissal of the complaint against Judge Quiroz due to the existence of appropriate judicial remedies.
Referral of the charges against the respondent sheriffs to the Executive Judge of the RTC in Pasig City for further investigation and recommendation.

The cases were later consolidated (by Resolution dated February 23, 2005) and referred to RTC Judge Florito S. Macalino.
During the investigation, respondent Sheriff Pangilinan passed away.
In subsequent reports and evaluations (including the Investigating Judge’s Report on December 10, 2007, and the OCA’s Evaluation on August 12, 2008), it was found that:

There was insufficient evidence to substantiate the charges of misconduct against Sheriff Garrobo.
The allegations against Judge Quiroz, including the counter-charges of corruption, lacked compelling evidence.

Ultimately, the administrative complaints against both Judge Quiroz and the respondent sheriffs were dismissed.

Whether Judge Quiroz’s issuance of the writ of execution was proper given that the Court of Appeals’ decision permitting execution had not yet become final and executory.
Whether executing the writ against PSPI, a non-party to the original civil case, violated any procedural rules in light of the pending motion for reconsideration and absence of an entry of judgment.
Whether the duties and actions of the respondent sheriffs in implementing the writ were in compliance with their ministerial role and within the bounds of established court procedures.
Whether the administrative complaints against Judge Quiroz and the respondent sheriffs were the appropriate remedy, considering the availability of judicial avenues for contesting their orders and actions.
Whether the countercharges of corruption and misconduct levelled by Judge Quiroz against Sheriff Garrobo were supported by sufficient evidence to justify disciplinary action.