Facts:

The case involves complainant Pedro San Jose and respondent Benjamin Centeno, a Deputy Sheriff of the Regional Trial Court in Sta. Cruz, Laguna. The events leading to the complaint occurred in the context of two civil cases, specifically Civil Cases Nos. 798 and 799. On June 30, 1986, the Municipal Trial Court of Pila, Laguna, issued a Writ of Execution ordering the demolition of nipa houses owned by defendants Danilo Salcida and Leonisa Aleta in Civil Case No. 798. This order required the execution to be carried out within sixty (60) days from the sheriff’s receipt of the writ. However, the respondent allegedly failed to enforce the order, and the complainant filed a sworn complaint on November 6, 1989, raising issues of ignorance of the law, neglect of duty, and disregard of court orders.

On October 26, 1988, a similar writ was issued in Civil Case No. 799 concerning the removal of a house owned by Mario de Leon. By September 1989, the defendants had not effectively complied

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Facts:

Background of the Complaint

• Pedro San Jose, the complainant and plaintiff in two civil cases, filed a sworn complaint on November 6, 1989, against Benjamin Centeno, Deputy Sheriff of Sta. Cruz, Laguna.
• The complaint charged respondent with ignorance of the law, neglect of duty, and disregard of court orders in connection with Civil Cases Nos. 798 and 799.
• Both cases involved writs of execution issued by the Municipal Trial Court of Pila, Laguna, which ordered the removal and demolition of houses occupied by the defendants.

Chronology and Execution of the Writs

• In Civil Case No. 798:

- A writ of execution was issued on June 30, 1986 to demolish the nipa houses belonging to defendants Danilo Salcida and Leonisa Aleta. - The writ mandated execution within sixty (60) days upon receipt. - Complainant alleged that Centeno failed to implement the writ despite the lapse of the prescribed period. - A writ of execution was issued on October 26, 1988 (notwithstanding an initial reference to 1989) to remove and demolish the house of Mario de Leon. - It was reported that part of the house was demolished in September 1989 by the defendant, even though he continued occupying the remaining portion. - The report on the execution in this case was filed by respondent on April 4, 1989, considerably later than the anticipated timeline.

Actions and Allegations by the Parties

• The Complainant’s Assertions:

- San Jose claimed that respondent’s delayed submission of his report (three years for Civil Case No. 798 and one year for Civil Case No. 799) amounted to neglect of duty. - He further asserted that despite having advanced funds (P517.00) for expenses related to demolition, Centeno failed in his duty to timely report and execute the writs. - In his testimony, San Jose maintained that discrepancies existed in respondent’s account, particularly regarding the transfer and demolition of properties. - In his comment dated June 20, 1990, Centeno noted that a similar complaint had been filed against him before the Office of the Ombudsman. - He alleged that, via mediation by the Deputy Ombudsman for Luzon, an amicable settlement had been reached which involved San Jose providing laborers for demolition and securing an Alias Writ of Execution. - Centeno asserted that he had, under strained circumstances due to San Jose’s non-compliance with their agreement, proceeded to secure laborers at an increased cost. - San Jose, in his reply on July 20, 1990, repudiated these allegations as “all lies and artificial” and insisted on the reality of the delayed report filings.

Investigation and Findings of the Court

• Administrative Proceedings:

- On July 18, 1990, the case was referred to the Executive Judge of the Regional Trial Court of Sta. Cruz, Laguna, for investigation. - Due to San Jose’s sickly condition, a motion was filed to transfer the investigation venue to the RTC in Manila. On January 13, 1992, the court ordered that the records be forwarded to Manila. - Ultimately, the case was raffled to Branch 36, presided over by Judge Wilfredo P. Reyes. - The investigator established that although the writ in Civil Case No. 798 was eventually executed, the report was filed three years late. - Evidence revealed inconsistencies in San Jose’s own testimony regarding the transfer of the property and his knowledge of such actions. - The investigation noted that San Jose attempted to include other houses on his lot in the writ of execution to leverage rental payments from additional occupants. - The report emphasized that the respondent, as an officer of the court, was required to make periodic reports and to promptly execute judicial orders. - It was noted that any additional amount received (P517.00 rather than an earlier request of P400.00) was not for personal gain but solely for the execution process. - The investigative findings pointed to a clear neglect in duty on the part of the Deputy Sheriff for delaying the critical report filing.

Conclusion Drawn from the Facts

• The facts demonstrated that the Department of the Sheriff’s office delayed the execution report far beyond the prescribed period.
• Such a delay was seen as detrimental to the swift administration of justice and was aggravated by the inconsistencies in San Jose’s version of events.
• The investigation underscored the duty of sheriffs to ensure orderly and prompt execution of court orders, regardless of extraneous circumstances or administrative complications.

Issue:

Whether the respondent (Deputy Sheriff Benjamin Centeno) neglected his official duty by failing to execute the writs of execution within the prescribed period.

• Did the tardy submission of his report, three years in one case and one year in another, violate the mandated timeline for enforcing court orders?
• Can the respondent’s actions, despite eventual execution, be characterized as a dereliction of duty that undermined the efficiency of judicial processes?

Whether the alleged ambivalence and inconsistencies in the complainant’s testimony regarding property transfers affect the determination of negligence.

• What role do the contradicting statements and evidence provided by Pedro San Jose play in assessing the overall conduct of the enforcement process?
• How does the discrepancy in timelines and the subsequent mediation agreement factor into respondent’s accountability?

Whether the imposition of a fine and a stern warning is a sufficient remedy to deter similar instances of neglect in the future.

• Does the sanction imposed adequately address the breach of duty regarding timely reporting and execution?
• What message is sent to other officers when such delays occur in the administration of justice?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)