Title
Vda. de Enriquez vs. Bautista
Case
A.M. No. RTJ-99-1439
Decision Date
May 9, 2000
Complainant accused judge of soliciting gifts and sheriff of demanding money in an ejectment case. Judge exonerated; sheriff suspended for misconduct.

Case Summary (G.R. No. 217414)

Complaint and Allegations

Virginia Villaluz filed a complaint against Judge Bautista and Deputy Sheriff Montes, alleging that they solicited payment in exchange for favorable judicial actions and delayed execution of a court order, causing her embarrassment and humiliation. The complaint was formally registered as Administrative Case No. RTJ-99-1439 and was subsequently referred for investigation and recommendation to the Court of Appeals.

Investigation Process

Honorable Salvador J. Valdez, Jr., an Associate Justice of the Court of Appeals, conducted a thorough investigation and prepared an evaluation report summarizing his findings. The complainant contended that she requested an "Alias Writ of Execution" for an ejectment case (Civil Case No. 4632-V-95) but faced undue delays and demands for payment from the Deputy Sheriff.

Events Leading to the Complaint

Initially, Respondent Judge Bautista issued writs of demolition on April 22 and 24, 1997. However, these writs were subsequently suspended without clear communication to the complainant. According to Villaluz, Deputy Sheriff Montes demanded ₱20,000 from her for demolition expenses and solicited gifts multiple times during the case's proceedings. Even on the scheduled demolition date, the action was halted at the last minute based on an uncommunicated decision from the Judge.

Respondent's Defense

In his defense, Judge Bautista denied the allegations and explained that the suspension of the writ was based on humanitarian grounds to prevent the displacement of the defendants. He later inhibited himself from the case due to a possible conflict of interest but eventually resumed hearing the case. Deputy Sheriff Montes contradicted the allegations, asserting that the amounts he received from Villaluz were for actual expenses incurred in the execution process.

Testimonies and Evidence

During the investigation, the Judge admitted to sending personal letters to a relative but denied any correspondence with the complainant. His statements suggested an effort to separate personal matters from his official duties. The Deputy Sheriff claimed that the amounts collected were used for legitimate expenses related to the demolition process and provided a breakdown of how the funds were utilized.

Investigating Justice's Findings

Justice Valdez concluded that while the complaint against Judge Bautista lacked substantial evidence, his conduct reflected a need for caution to avoid any appearance of impropriety. T

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