A.M. No. P-24-150 - Ignacio vs. Balading

In 2011, the Metropolitan Trial Court (MTC) decided the case People v. Reyes, involving a complaint under the Bouncing Checks Law (Batas Pambansa Blg. 22).
The accused, Carolina Reyes, was acquitted criminally but held civilly liable to Romeo Aznar for PHP 128,500.00.
A Writ of Execution was issued on October 25, 2012, to enforce the civil judgment.

On January 4, 2013, Sheriff Paul Christopher T. Balading went to Megabuilt Enterprises, a hardware store in Batasan, Quezon City, accompanied by Aznar and unidentified "hatak boys."
Balading levied hardware materials from Megabuilt and loaded them into a van.

Froilan E. Ignacio, the registered owner of Megabuilt Enterprises, filed an administrative complaint against Balading on January 10, 2013.
Ignacio alleged Balading was armed, did not identify himself as a sheriff, and forcibly entered the store despite resistance from Ignacio's employees.
The levied properties were alleged to be worth not less than PHP 500,000, exceeding the court-ordered amount.
Ignacio submitted sworn statements from employees and CCTV footage to substantiate his claims.

Despite multiple directives, Balading filed a comment only on June 2, 2016.
He admitted going first to Reyes's house and offering money to her helpers to get vehicle keys. Upon failure, he tried to levy assets at Kingplus Construction and Hardware Supply but backed off when Reyes's counsel arrived.
Balading claimed Reyes was hiding in Megabuilt and that Ignacio was her husband.
Denied any robbery occurred, citing presence of a nearby police station.
He sold the levied items at public auction and denied levying some items mentioned by Ignacio.

The Supreme Court referred the complaint to the Office of the Court Administrator (OCA) for evaluation.
The OCA recommended further investigation by the executive judge due to factual issues, and fined Balading PHP 10,000.00 for insubordination for late comment filing.
The executive judge reported difficulty in notifying Balading due to his absence and pending criminal cases against him; conducted hearings nonetheless.
Ignacio confirmed sole proprietorship of Megabuilt and denied any relationship of Reyes as co-owner or common-law wife.
The judge found Balading guilty of grave abuse of authority, noting failure to prove Reyes’s interest in Megabuilt and forcible removal of goods without due process.

The Judicial Integrity Board confirmed grave abuse of authority by Balading, emphasizing no proof of Reyes's interest in Megabuilt and procedural lapses in enforcement.
They recommended forfeiture of all benefits (except accrued leave), disqualification from public office, and administrative penalties.
The Supreme Court en banc accepted the case and found Balading guilty of grave abuse of authority.

Whether Sheriff Balading committed grave abuse of authority in enforcing the Writ of Execution against Megabuilt Enterprises owned by Ignacio.
Whether Balading's actions violated procedural and ethical standards expected of court sheriff officers.
Proper penalty for Balading considering he was dropped from service rolls.