Case Digest (A.M. No. P-10-2837)
Facts:
PO2 Patrick Mejia Gabriel v. William Jose R. Ramos, A.M. No. P-10-2837 (formerly OCA I.P.I. No. 07-2613-P), August 25, 2010, Supreme Court Third Division, Brion, J., writing for the Court.Complainant PO2 Patrick Mejia Gabriel, a Philippine National Police member assigned as Chief Investigator at San Teodoro, Oriental Mindoro, filed an administrative complaint for grave misconduct with the Office of the Court Administrator (OCA) on July 13, 2007, against William Jose R. Ramos, Sheriff IV of the Regional Trial Court, Branch 166, Pasig City. Gabriel alleged that on May 10, 2007, Ramos, together with several persons and in conspiracy with former Municipal Mayor Manuel Roxas Bae, entered the home of Adelaida Caeg Hael in Barangay Calsapa and handed out two P500 bills and a sample ballot to induce votes for a mayoralty candidate; sworn statements by Adelaida and Ariel Hael and a related information (I.S. No. 07-12386) before the provincial prosecutor were attached.
The OCA required Ramos to comment; Ramos filed a comment (September 6, 2007) denying the allegations, admitting only that he was in Barangay Calsapa to buy charcoal and that he spoke with Ariel Hael but not about politics, contending the charges were false and retaliatory because he had filed robbery and administrative charges against policemen including the complainant. The OCA prepared a report (dated August 28, 2008) noting the conflicting accounts and recommending referral to the Executive Judge of the RTC, Pasig City, for formal investigation so the respondent could confront his accusers.
Acting on the OCA report, the Court referred the case to Executive Judge Amelia C. Manalastas, RTC, Pasig City, for investigation, report and recommendation. Judge Manalastas conducted hearings and set conference dates; notifications were issued for December 8 and 15, 2008, but only respondent and his counsel appeared while the complainant failed to appear despite notice. The Executive Judge’s report (submitted January 26, 2009) found that the complainant failed to establish the allegations, described the complaint as appearing to be leverage prompted by Ramos’s prior complaint against Gabriel, applied the rule that the burden of proof in administrative proceedings lies with the complainant (citing Gotgotao v. Millora, 459 SCRA 340), and recommended dismissal for lack of evidence.
The Supreme Court, through the Third Division, ad...(Pro-only)
Issues:
- Whether respondent Sheriff William Jose R. Ramos may be held administratively liable for grave misconduct based on the alleged vote-buying incident of May 10,...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)