AM MTJ 10 1771; (February, 2013) (Digest)
G.R. No. A.M. No. MTJ-10-1771. February 13, 2013.
VICTORIANO G. MANLAPAZ, Complainant, vs. JUDGE MANUEL T. SABILLO, Municipal Circuit Trial Court, Lamitan, Basilan, Respondent.
FACTS
Complainant Victoriano Manlapaz alleged that in 1996, respondent Judge Manuel Sabillo, then a practicing lawyer and a wedding sponsor, sold him a house and lot for P2.4 million. After Manlapaz paid P920,000, the transaction was discontinued by mutual verbal agreement, with Sabillo undertaking to refund the amount. Sabillo reneged, prompting Manlapaz to file a civil case. The Regional Trial Court (RTC) of Valenzuela City ruled in Manlapaz’s favor in 2003, ordering Sabillo to refund P920,000 plus damages. Sabillo’s appeal was dismissed by the Court of Appeals for non-payment of docket fees, rendering the RTC decision final and executory in 2007. A writ of execution was issued, but the sheriff found Sabillo had sold the property in 2004. Sabillo, then an incumbent judge, later paid only the attorney’s fees award of P100,000 during a meeting but failed to settle the principal and other damages, having previously offered a mere P400,000 as full settlement.
ISSUE
Whether respondent Judge Sabillo is administratively liable for willful failure to pay a just debt.
RULING
Yes, the Supreme Court found Judge Sabillo guilty of willful failure to pay a just debt under Section 8, Rule 140 of the Rules of Court. The Court emphasized that while it is not a collection agency, judiciary officials and employees are held to high standards of integrity in both public and private dealings. A “just debt” is an obligation adjudged by a court of competent jurisdiction, the existence of which is admitted by the debtor or is supported by evidence. Here, the final RTC judgment conclusively established Sabillo’s just debt. His pattern of conduct—failing to deliver the property, reneging on his refund undertaking, allowing a judgment to become final, selling the property to another buyer, offering a grossly inadequate settlement, and only partially paying the judgment award—demonstrated willfulness in avoiding payment. His eventual offer to pay via cashier’s check was deemed an afterthought that did not negate liability but only mitigated culpability. Accordingly, the Court imposed a fine of P40,000 with a stern warning, and directed him to settle his indebtedness within thirty days if still unpaid.