A.M. No. 02-8-198-MeTC; June 8, 2005
RE: CRIMINAL CASE NO. MC-02-5637 AGAINST ARTURO V. PERALTA AND LARRY C. DE GUZMAN, BOTH EMPLOYEES OF METC, BRANCH 31, QUEZON CITY

FACTS

Arturo Peralta, a Deputy Sheriff, and Larry De Guzman, the Branch Clerk of Court of MeTC, Branch 31, Quezon City, were charged with robbery (extortion). The case stemmed from a replevin suit where Peralta, as special sheriff, seized a vehicle from SPO3 Hernani Aga pursuant to a writ. Later, the court issued a resolution ordering Peralta to recover the same vehicle from the plaintiff and return it to SPO3 Aga. When Aga presented the resolution for implementation, Peralta and De Guzman demanded ₱5,000.00 from him. Aga reported the extortion to the NBI, leading to an entrapment operation. At the designated meeting place and after a failed attempt to retrieve the vehicle, Peralta and De Guzman assured Aga they would handle the recovery and instructed him to hand over the money. Upon receiving the marked cash, they were arrested by NBI agents. Forensic examination found fluorescent powder on De Guzman but not on Peralta.
In his comment, Peralta denied the extortion, claiming Aga offered them money for snacks and taxi fare out of insistence and that the complaint was an act of vengeance for the earlier seizure of his car. He argued it was improbable to extort a police officer. De Guzman did not file any comment.

ISSUE

Whether respondents Arturo Peralta and Larry De Guzman are administratively liable for Serious Misconduct and Dishonesty.

RULING

Yes, both respondents are guilty. The Supreme Court emphasized that all court personnel must adhere to the highest standards of integrity and propriety. Their conduct must be, and must appear to be, free from any impropriety. The factual circumstances, particularly the entrapment operation and the direct demand for money in exchange for the performance of an official duty, constitute clear evidence of Serious Misconduct and Dishonesty. The defense of frame-up or vengeance was rejected for being unsubstantiated and implausible, especially given the detailed account of the entrapment. The Court ruled that the act of demanding money in connection with official functions is a grave violation that erodes public trust in the judiciary.
The failure of De Guzman to file his comment was deemed an admission of the charges. For these grave offenses, the penalty of dismissal is mandatory under civil service rules. Consequently, the Court DISMISSED Arturo Peralta and Larry De Guzman from service with forfeiture of all benefits, except accrued leave credits, and with prejudice to re-employment in any government agency.