Facts:

The case involves an administrative complaint filed by the Bangko Sentral ng Pilipinas (BSP) against Executive Judge Enrico A. Lanzanas of the Regional Trial Court (RTC), Branch 7, Manila; Clerk of Court Jennifer Dela Cruz-Buendia; and Deputy Sheriff Carmelo V. Cachero. The complaint was initiated on November 12, 2003, alleging that the respondents committed culpable violations of their official duties by allowing the withdrawal and release of garnished funds amounting to ₱97,388,468.35 to the Philippine Bank of Communications (PBCOM) and its counsel, who were not parties to the case. The BSP claimed that Cachero fraudulently caused the release of the funds, while Dela Cruz-Buendia was accused of usurpation of judicial functions and malversation of public funds. Judge Lanzanas was charged with gross negligence in his duties.

The background of the case stems from Civil Case No. 99-95993, where the BSP was the plaintiff against Orient Commercial Banking Corporation and others...

Facts:

Case Background
The Bangko Sentral ng Pilipinas (BSP) filed an administrative complaint against Executive Judge Enrico A. Lanzanas, Clerk of Court Jennifer dela Cruz-Buendia, and Deputy Sheriff Carmelo V. Cachero for allegedly allowing the unauthorized withdrawal and release of garnished funds amounting to P97,388,468.35 in favor of the Philippine Bank of Communications (PBCOM) and its counsel, who were not parties to the case.

Writ of Attachment
In Civil Case No. 99-95993, BSP v. Orient Commercial Banking Corporation et al., Judge Rosmari D. Carandang of RTC Manila Branch 12 issued a Writ of Attachment on January 19, 2000, against the defendants' assets, including garnished rental payments from mall tenants. These funds were deposited in a Land Bank of the Philippines (LBP) account under the custody of the court.

Unauthorized Withdrawals
On May 12, 2003, Deputy Sheriff Carmelo Cachero served a Notice to Deliver Garnished Amount based on a writ of execution issued by Judge Guillermo G. Purganan of RTC Manila Branch 42 in Civil Case No. 01-101190 (PBCOM v. Spouses Jose C. Go and Elvy T. Go). This led to the withdrawal and release of P85,631,690.38 to PBCOM, with LBP checks co-signed by Judge Lanzanas and dela Cruz-Buendia. Further withdrawals totaling P11,344,990.74 and other amounts were made on May 15 and 16, 2003.

BSP’s Protest
The BSP argued that the withdrawals were irregular since the garnished funds were in custodia legis under RTC Branch 12 and could not be released without the proper court’s permission. BSP also claimed that the case records had already been transmitted to the Court of Appeals by April 22, 2003, rendering RTC Branch 42 without jurisdiction.

Respondents' Defenses

• Judge Lanzanas denied culpability, stating he signed the checks in a ministerial capacity as executive judge and had no knowledge of any irregularity.
• Clerk of Court Dela Cruz-Buendia claimed she acted in good faith, following standard operating procedures in processing the checks and supporting documents.
• Deputy Sheriff Cachero argued he was merely enforcing a lawful writ of execution and had no intention to commit irregularities.

Issue:

1. Whether the respondents violated their duties by allowing the release of garnished funds in custodia legis without proper authorization.
2. Whether the respondents can be held administratively liable for usurpation of authority, malversation of public funds, and other charges.
3. Whether the respondents acted in good faith in performing their ministerial duties.

Ruling:

The Court dismissed the charges against Judge Lanzanas for insufficiency of evidence. However, Deputy Sheriff Carmelo Cachero was found guilty of inefficiency and incompetence in the performance of his duties and was suspended for nine (9) months without pay. Clerk of Court Jennifer dela Cruz-Buendia was found guilty of simple neglect of duty and was suspended for three (3) months without pay. Both were sternly warned against repeating similar offenses. All other charges, including usurpation of authority and malversation of public funds, were dismissed for lack of evidence.

Ratio:

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