G.R. No. A.M. No. P-55, A.M. No. P-98, A.M. No. P-99 July 17, 1975
ESPERANZA SARMIENTO and EMERENCIANA PAGARAGAN, complainants, vs. FLORENCIO M. DAGDAG and ANTONIO D. NITURA, respondents.

FACTS

These consolidated administrative cases involve charges of dishonesty, extortion, and misconduct against Antonio D. Nitura, Clerk of Court, and Florencio M. Dagdag, a clerk, both of the Court of First Instance of Isabela, Branch IV. In A.M. No. P-55, Esperanza Sarmiento alleged that Dagdag extorted P80 and two bundles of tobacco leaves to set her cadastral case for hearing. In A.M. No. P-99, Sarmiento charged Nitura with extorting P90 to expedite his report as a commissioner in her civil case and alleged he later caused an order lifting a default against her opponents. In A.M. No. P-98, Emerenciana Pagaragan accused Nitura of deceitfully receiving P2,000 from her under a false court order and issuing a receipt for only P1,800.
The respondents denied all allegations. Nitura explained that delays in Sarmiento’s case were due to her counsel’s request and the judge’s absence, and he promptly submitted his report. Regarding Pagaragan’s money, he asserted it was transmitted to the opposing party per a stipulation, with a P200 deduction being a loan later returned. The cases were referred for investigation, but both complainants repeatedly failed to appear for hearings despite due notice.

ISSUE

Whether the respondents, Antonio D. Nitura and Florencio M. Dagdag, are administratively liable for dishonesty, extortion, and misconduct based on the complaints.

RULING

The Supreme Court dismissed all charges for lack of substantiation. The ruling hinges on the fundamental principle that in administrative proceedings, the burden of proof lies with the complainant. The complainants’ failure to appear and present evidence during the investigation left their serious accusations unsupported by any credible proof. The Court could not rely solely on the unverified allegations in the complaints.
Examining the records, the Court found the respondents’ explanations credible and corroborated by documentary evidence. For Sarmiento’s charges, the timeline showed Nitura performed his duties without undue delay—the evidence was received on June 8, 1971, and his report was submitted on June 11, 1971. The lifting of the order of default was a judicial act by the judge, not attributable to Nitura. For Pagaragan’s charge, the record confirmed Nitura delivered the P2,000 to the intended recipient, Benito Pua, as part of a court-monitored agreement. The complainants’ non-appearance, without justification, fatally undermined their capacity to prove their case. Consequently, without clear, convincing, and substantial evidence to overcome the presumption of regularity in the performance of official duties, the administrative complaints must fail.