Case Summary (A.M. No. RTJ-09-2186, RTJ-09-2187)
Background of the Case
These administrative complaints arise from a conflict stemming from the enforcement of a writ of execution in Civil Case No. 59264, where Judge Alex L. Quiroz of Branch 156 of the Regional Trial Court (RTC) of Pasig City issued a writ following a court decision in favor of Fruehauf Electronics Philippines, Inc. The writ aimed to execute a judgment against Philips Semiconductors Philippines, Inc. (PSPI), which was identified as the local subsidiary of Signetics Corp., U.S.A. The contested order was issued on October 9, 2003, during Judge Quiroz's absence due to illness, and proceeded with implementation despite legal objections from the complainants, who claimed that the appellate court's decision was not yet final.
Legal Proceedings and Claims Made
The complainants filed a motion to set aside the October 9 order before the appellate court, arguing that the decision by the Court of Appeals permitting execution was not yet final and executory pending their motion for reconsideration. The complainants' allegations included that execution was carried out without the necessary motions being filed, and the issuance of the writ was done motu proprio while lacking a certified entry of judgment as mandated by the Rules of Court.
Responses and Initial Findings
Judge Quiroz defended his issuance of the writ by asserting it complied with the appellate court's directives. He contended that plaintiffs only needed to attach a certified copy of the judgment rather than an entry of judgment as purported by the complainants. The sheriffs Garrobo and Pangilinan echoed the view that their duty to implement the writ was ministerial and did not encompass discretion concerning its execution.
Court Evaluation and Resolution
The Office of the Court Administrator (OCA) investigated the matter and concluded that the administrative complaint was not the correct avenue to challenge Judge Quiroz’s order since judicial remedies were still viable. The issues presented were deemed too technical for administrative resolution, which led to the recommendation that the complaint against Judge Quiroz be dismissed. Conversely, charges against the responding sheriffs were referred for formal investigation due to the conflicting accounts regarding the execution of the writ.
Final Recommendations and Dismissal
The Court En Banc found merit in the recommendations of the OCA. Charges against Sheriff Garrobo and Sheriff Pangilinan were dismissed as they had acted in accordan
...continue readingCase Syllabus (A.M. No. RTJ-09-2186, RTJ-09-2187)
Case Overview
- This syllabus covers two administrative complaints against Judge Alex L. Quiroz and Sheriffs Edwin V. Garrobo and Mario Pangilinan, stemming from the issuance and implementation of a Writ of Execution in Civil Case No. 59264, titled "Fruehauf Electronics Philippines, Inc. v. Signetics Corp., U.S.A."
- The complaints were initiated by Attorneys Nelson T. Antolin and Diosdado E. Trillana, representing Philips Semiconductors Philippines, Inc. (PSPI), and the cases were decided by the Supreme Court En Banc on July 14, 2009.
Background of the Case
- The case originated from a decision by the Regional Trial Court (RTC) of Pasig City, which favored Fruehauf Electronics Philippines, Inc. in 1996.
- After the decision was affirmed by the Court of Appeals, a Motion for Execution was filed on May 21, 2001, which Judge Quiroz initially denied directing execution against PSPI, stating it was not a party to the original case.
- This denial was contested by Fruehauf through a petition for Certiorari and Mandamus, leading to a reversal by the Court of Appeals in a decision dated September 10, 2003, which ordered Judge Quiroz to issue a writ of execution against PSPI.
Proceedings Under the Writ of Execution
- In compliance with the appellate court's decision, Judge Quiroz issued a writ of execution on October 9, 2003, designating Sheriff Edwin V. Garrobo to execute it.
- Sheriffs Garrobo and Mario Pangilinan proceeded to implement the writ in Cabuyao, Laguna, despite object