Title
Supreme Court
Romero vs. Villarosa, Jr.
Case
A.M. No. P-11-2913
Decision Date
Apr 12, 2011
Sheriff Villarosa dismissed for grave abuse, dishonesty, and failure to remit funds promptly, violating court rules and ethical standards.

Case Summary (A.M. No. P-11-2913)

Complaint Process and Investigation

Romero filed her sworn complaint on July 4, 2007. The Office of the Court Administrator (OCA) referred the case to Judge Apolinario M. Buaya on September 15, 2008, for investigation. The Investigating Judge submitted a report on January 18, 2010, which ultimately led to further evaluation by the OCA before being taken up by the court.

Facts of the Case

The underlying dispute stems from a civil case, Civil Case No. 462, in which Romero was awarded damages in a compromise agreement dated December 8, 2005. The spouses Valentin and Enriqueta Laurente committed to pay Romero a total of P30,000, with specific payment deadlines. While Romero received an initial payment of P10,000, the remaining P20,000 was not fully received as per the agreement.

Failure to Remit Amounts

After receiving partial payments, Villarosa was tasked with executing the writ of execution but faced allegations of misconduct. Notably, despite Villarosa attesting that he had received P20,000 from Enriqueta Laurente and confirming in a certification dated May 9, 2007, that the full amount had been paid, Romero disputed this claim, stating she had not received the full sum.

Allegations of Misconduct

Sheriff Villarosa initially denied wrongdoing but admitted to receiving various sums amounting to P13,000 from Enriqueta Laurente. He asserted that he remitted P10,000 to Romero and claimed that a remaining balance of P3,000 was given to the Clerk of Court, a statement which lacked credible support, leading to heightened suspicion regarding his handling of the funds.

Irregularities and Findings

The Investigating Judge identified multiple irregularities in Villarosa’s handling of the payments, noting discrepancies in the amounts he claimed to have turned over to Romero versus the amounts received from Enriqueta Laurente. This led to the conclusion that he failed to adhere to established protocols under Section 9 of Rule 39 of the Rules of Court for executing judgments for monetary claims.

Legal Standards and Duties of a Sheriff

Under the pertinent rules, sheriffs are required to enforce judgments promptly and diligently, ensuring all payments are turned over to the Clerk of Court within the same day they are received. Failure to follow this protocol signifies grave abuse of authority and conduct unbecoming of a public servant.

Conclusions of the Court

Following a comprehensiv

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