Title
Abadiano vs. Regalado
Case
A.M. No. P-11-2944
Decision Date
Jul 27, 2011
A sheriff's unauthorized actions, including accepting a Special Power of Attorney and threatening heirs during a property dispute, led to a misconduct ruling and a ₱10,000 fine.
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Case Summary (A.M. No. P-11-2944)

Case Overview

  • Complainants: Carol A. Abadiano, Cleofe Abadiano-Bonachita, Ryan M. Abadiano, Cherry Mae M. Abadiano
  • Respondent: Generoso B. Regalado, Sheriff IV, Regional Trial Court, Branch 16, Cebu City
  • Date of Filing: February 4, 2010
  • Nature of Complaint: Grave Abuse of Authority, Oppression, and Gross Misconduct

Background Facts

  • The complainants are heirs of the late spouses Pablo and Teodora Abadiano, recognized by the Regional Trial Court (RTC) Branch 13 as entitled to shares in their properties.
  • Their brother, Armando Abadiano, without informing the complainants, secured a loan against their late father's property for medical expenses, exceeding the required amount.
  • A foreclosure petition was filed by the mortgagee, Alfredo Genosolango, leading to a Writ of Possession served by Regalado.
  • The complainants filed a complaint for the annulment of the loan agreement while the Writ of Possession was in effect.

Allegations Against Regalado

  • Regalado allegedly prevented the complainants from collecting rents and threatened them with estafa if they insisted.
  • He claimed to act as Attorney-in-Fact for Genosolango, showing a special power of attorney that his actions were authorized.

Respondent's Defense

  • Regalado denied the allegations, asserting that he acted within his legal authority and did not improperly use the Special Power of Attorney.
  • He contended that his actions were conducted in the performance of his duties as a sheriff.

Findings of the Office of the Court Administrator (OCA)

  • The OCA found the complainants’ account more credible than Regalado's denial, noting the improper conduct by allowing himself to act as Attorney-in-Fact for Genosolango without court knowledge.
  • Conflict of Interest: Regalado’s actions constituted a conflict of interest due to his dual role.

Conclusions and Recommendations

  • Regalado was recommended to be found guilty of Conduct Prejudicial to the Best Interest of the Service and fined ₱10,000, with a warning against future infractions.
  • The Court highlighted the importance of ethical standards for judiciary employees to maintain public trust.

Court’s Final Decision

  • Regalado was ultimately found guilty of Misconduct.
  • Penalty: A fine of ₱10,000 was imposed with a stern warning against recurrence of similar offenses.

Key Legal Principles

  • Judicial Conduct: Officers of the judiciary must adhere to high ethical standards, avoiding any appearance of impropriety.
  • Conflict of Interest: Actions that jeopardize the rights of in...continue reading

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