A.M. No. RTJ-06-2216 - Rodriguez vs. Eugenio

Complainant Sammy Rodriguez, uncle of criminal accused Sonny Acbay, filed an administrative complaint.
Respondent Jaime C. Eugenio functioned as a Process Server at the Caloocan City Regional Trial Court (RTC).
The complaint pertained to allegations of grave misconduct amounting to violations under Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).

In or around June 2004, Sammy Rodriguez, seeking information about his nephew’s pending criminal case (Criminal Case No. C-69159 for Robbery), was directed by Public Attorney’s Office counsel de officio, Atty. Isabelo E. Sicat, to follow up at the RTC’s staff room.
On his way to RTC-Branch 121, Rodriguez encountered respondent Eugenio, who offered to secure the dismissal of the criminal case in exchange for money.
The transactions reportedly included:

An initial demand of ₱300.00, which was promptly paid.
A subsequent solicitation of ₱500.00, allegedly designated for Meycauayan policemen.
An additional aggregate payment amounting to ₱1,700.00 over several occasions.

On September 14, 2004, following a reset of the criminal case, Rodriguez was told—after consulting Atty. Sicat—that another ₱1,500.00 (₱1,000.00 allegedly for Atty. Sicat and ₱500.00 for transportation) would secure the case’s dismissal.
Lacking immediate funds, Rodriguez promised to deliver the amount the following day.

On September 15, 2004, with the assistance of broadcast personality Erwin Tulfo of ABS-CBN, Rodriguez initiated an entrapment operation by presenting a white envelope containing ₱1,500.00 to the respondent.
This operation, conducted near the Judicial Complex and subsequent to multiple extortion attempts, led to the apprehension of respondent Eugenio.
Post-arrest developments included the filing of a separate robbery case (Criminal Case No. C-71514) against the respondent.

The RTC, Branch 121, originally endorsed the administrative complaint, and the Office of the Court Administrator (OCA) recommended that Eugenio be dismissed from service with forfeiture of retirement benefits (except accrued leave credits).
Although Rodriguez later submitted an Affidavit of Desistance in the related criminal case—stating a lack of criminal intent and a misunderstanding—the administrative complaint proceeded based on its own merits.
Evidence presented included:

Testimony and affidavit evidence by the complainant detailing each monetary transaction and subsequent instructions from respondent Eugenio.
The laboratory report from the Philippine National Police indicating the presence of ultraviolet fluorescent powder on the respondent’s clothing, consistent with the modus operandi of receiving the bribe.
Atty. Sicat’s affidavit denying any instruction to demand money or receipt thereof, establishing that the respondent acted independently.

Whether the unilateral act of desistance (as evidenced by the Affidavit of Desistance in a related criminal case) could impede or nullify the administrative proceedings against respondent Eugenio.
Whether the public interest in maintaining the integrity of the judiciary required the continuation of the administrative process regardless of the complainant’s subsequent disposition.

Whether the evidence adduced, including the series of monetary transactions and the results of the entrapment operation, was sufficient to establish that respondent solicited and received money in connection with a favorable disposition of a criminal case.
Whether respondent's defenses—including claims of frame-up, absence of intent, and denial of monetary transactions—were sufficiently supported by credible, positive evidence.

Whether the conduct of a process server, with no authority to influence case outcomes, constituted gross misconduct under the established norms and rules of judicial conduct.
Whether the sanction of dismissal from service with forfeiture of benefits was justified in view of the gravity of the misconduct and the need for institutional reform to preserve public confidence in the judiciary.