Title
Olandria vs. Fuentes, Jr.
Case
A.M. No. P-18-3848
Decision Date
Jun 27, 2018
Sheriff failed to inventory attached properties, allowing plaintiff to withdraw items unsupervised, leading to a finding of simple neglect of duty.

Case Summary (A.C. No. 8261, 8725)

Allegations Against Respondent

Complainant alleged that he was one of the defendants in a money claim, and the RTC-Cebu issued a writ of preliminary attachment in favor of Pump & Go Power Fuel, Inc. Respondent was tasked with enforcing this writ but allegedly failed to protect complainant's interests. Complainant claimed that respondent allowed plaintiff's representatives to control and subsequently withdraw items from the attached properties—seven gasoline stations—without that being properly documented or supervised.

Respondent's Defense

In his Comment, respondent maintained he did not lose control of the attached properties because private security guards were posted at each location. He argued that removing the gasoline tanks to a bonded warehouse was impractical and stated that he was not required to oversee the withdrawal of the items as they were taken out in accordance with a compromise agreement sanctioned by the RTC. Additionally, he claimed the court had not mandated him to render an inventory post-withdrawal.

Findings by the Office of the Court Administrator (OCA)

The OCA recommended that respondent be found guilty of simple neglect of duty, as he failed to maintain custody of the attached properties and to prepare an inventory as required by the court's orders. While acknowledging that the plaintiff was authorized to withdraw items, the OCA emphasized that respondent should have ensured his presence during these withdrawals to protect the interests of both parties. The recommended penalty was a fine of P5,000.00.

Court's Ruling on Responsibilities

The court observed that Rule 57 of the Rules of Court clearly states the sheriff's duties following a writ of attachment, including the obligation to submit a report with a detailed inventory of attached properties. Notably, respondent admitted to failing to create the required inventory and did not oversee the withdrawals, which amounted to simple neglect of duty. The court reiterated that a sheriff is expected to fulfill these responsibilities diligently.

Analysis of Neglect of Duty

The court defined simple neglect of duty as a failure to provide adequate attention to one's responsibilities, often due to carelessness or indifference. In confirming the OCA's findings, the court highlighted that the respondent's inaction negatively impacted complainant’s interests and violated judicial processes, underlining the seriousness of neglect within public service roles.

Consideration of Penalties

While the OCA classified the infraction as a less grave

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