G.R. No. 238516 - People vs. Rodriguez y Martinez

Mary Ann C. Ito filed an administrative complaint against several employees of the Regional Trial Court (RTC), Silay City, including Eric B. De Vera (Clerk of Court VI), May Nene Las Piñas (Legal Researcher), Vicente V. Quinicot (Sheriff IV), Mae Vercille H. Nallos (Clerk II), and Lucia Santillan (Stenographer).
The charges stemmed from Cadastral Case No. 186-40, involving a petition for the issuance of a writ of possession filed by Ito against spouses Analyn and Shigeo Nishio.

On March 25, 1998, the Nishios borrowed money from Ito and mortgaged their land in Barangay Mambulac, Silay City, as security. The loan was due on or before March 25, 1999.
On February 2, 1999, Ito left for Japan.

On May 11, 1999, while Ito was in Japan, De Vera visited her residence and advised her aunt, Julieta Alve, to have Ito file a petition for extrajudicial foreclosure of the mortgaged property.
De Vera allegedly solicited P13,040.00 from Ito for filing fees, publication fees, and sheriff’s expenses. The amount was delivered to him, but the petition was not filed until June 28, 1999, after Ito demanded the return of her money.
De Vera admitted receiving the amount but claimed it was for foreclosure expenses. He denied soliciting the money and stated he was merely advising Ito’s aunt.

Quinicot, the sheriff, allegedly refused to serve the writ of possession on the Nishios, calling the case "troublesome."
Quinicot claimed he could not implement the writ immediately as he was waiting for the order to become final.

Ito accused Las Piñas and Nallos of falsifying the date of receipt of an order by Atty. Francisco Alisan, counsel for the Nishios.
They explained that the date was corrected to reflect the true date of receipt, as the original date (November 7, 1999) was a Sunday, and personal service of court processes is not done on weekends.

Santillan, the stenographer, was accused of demanding P500.00 to serve the order on a holiday. She denied the allegation, stating she had no role in serving court processes.

Ito later filed a motion to withdraw her complaint, stating she no longer wished to pursue the case. Despite this, the Office of the Court Administrator (OCA) proceeded with the investigation.

Whether the respondents committed dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service.
Whether the withdrawal of the complaint by the complainant absolves the respondents of administrative liability.
Whether the OCA’s findings and recommendations are supported by the evidence.