Case Digest (A.M. No. RTJ-99-1439)
Facts:
In the case of Virginia Villaluz vda. de Enriquez vs. Judge Jaime F. Bautista and Deputy Sheriff Jaime T. Montes, Administrative Case No. RTJ-99-1439 was initiated on May 9, 2000. The complaint was lodged by Virginia Villaluz vda. de Enriquez against the respondents, Judge Bautista and Deputy Sheriff Montes, for alleged gross misconduct in connection with an ejectment suit (Civil Case No. 4632-V-95) handled by the Regional Trial Court, Branch 75 of Valenzuela, Metro Manila. Villaluz accused Judge Bautista of soliciting payments for favorable decisions and delaying the execution of the writs of demolition, which caused her embarrassment and humiliation.
The complainant filed a "Motion for Issuance of Alias Writ of Execution" in April 1997, following which Judge Bautista issued two writs for demolition. However, the execution was postponed for unclear reasons. Villaluz claimed that during the entire span of the case, the judge repeatedly solicited gifts or favors in exc
Case Digest (A.M. No. RTJ-99-1439)
Facts:
- Complainant: Virginia Villaluz vda. de Enriquez, involved in an ejectment suit (Civil Case No. 4632-V-95) against co-owners of the disputed premises.
- Respondents:
- Judge Jaime F. Bautista – a Regional Trial Court judge in Valenzuela.
- Deputy Sheriff Jaime T. Montes – officer assigned to execute the writs of demolition.
Background of the Case
- The complainant filed a “Motion for Issuance of Alias Writ of Execution,” which led to the issuance of two writs of demolition by Judge Bautista on 22 April 1997 and 24 April 1997.
- The writs of demolition were later suspended for reasons initially unknown to the complainant, causing delays in the demolition process.
- Over a period of time—from 1995 to 1997—the respondent judge issued a total of 23 orders related to the case, during which he reportedly asked for gifts or other forms of consideration.
Initiation and Course of the Ejectment Proceedings
- Complainant's Claims Against Respondents
- Judge Bautista was accused of gross misconduct for allegedly soliciting consideration in exchange for a favorable decision and for delaying the demolition to cause humiliation to the complainant.
- Deputy Sheriff Montes was charged with demanding money (P20,000.00) for demolition expenses and failing to properly account for funds and expenditures.
- Specific Incidents Documented
- On the scheduled date of demolition (24 April 1997), the sheriff advised the complainant to engage security services (which she did) but no demolition team arrived as the demolition was temporarily held in abeyance by order of Judge Bautista.
- Subsequent orders and conflicting instructions were issued—such as the ex-parte motion for full enforcement on 15 May 1997—leading to demolition work commencing on 19 May 1997 and resuming on 22 May 1997 after a temporary two-day stoppage requested by governmental officials.
Allegations of Misconduct
- The complaint (Administrative Case No. RTJ-99-1439) was referred to the Court of Appeals for a thorough investigation, led by Honorable Salvador J. Valdez, Jr.
- During the investigation, extensive evidence was gathered including:
- The complainant’s sworn statements and testimony which at one stage inconsistently contradicted her initial allegations.
- Detailed affidavits and breakdowns of demolition expenses submitted by Deputy Sheriff Montes.
- A series of handwritten letters (Exhibits B, C, and D) admitted by Judge Bautista, which contained references to personal activities (such as a ballroom dancing invitation) and used terms like “abunuhan,” later explained as referring to non-official solicitations intended for personal relaxation outside regular judicial duties.
Judicial and Administrative Proceedings
- Judge Bautista acknowledged that the letters were his personal correspondence addressed to his niece (named Nanette), not to the complainant.
- The letters discussed matters such as instructions regarding “referrals” for a social (ballroom dancing) engagement after office hours.
- The exchange revealed that some of the language could be misinterpreted but was explained by the judge as personal and not indicative of judicial impropriety toward the complainant.
Content and Significance of the Handwritten Letters
- The investigation concluded that although Judge Bautista’s conduct fell short of the highest expectations of judicial decorum, there was insufficient evidence to sustain the charge of gross misconduct against him.
- In contrast, Deputy Sheriff Montes was found to have committed acts amounting to gross misconduct by:
- Soliciting sums without proper procedural safeguards (e.g., not obtaining judicial approval for the estimated demolition expenses).
- Failing to issue official receipts and to timely submit a proper liquidation of expenses.
Investigating Justice’ Findings
Issue:
- Whether Judge Jaime F. Bautista solicited any gifts or monetary consideration in exchange for a favorable decision in the ejectment suit; essentially, whether his conduct constituted gross misconduct.
- Whether Deputy Sheriff Jaime T. Montes committed gross misconduct by unilaterally demanding money for the demolition process and neglecting the procedural requirements for handling and liquidating such funds.
- Whether the administrative charges against the respondents should result in disciplinary measures, keeping in mind the integrity and ethics of the judicial officials involved.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)