G.R. No. P-02-1660. January 31, 2006.
JUDGE ELISEO C. GEOLINGO, complainant, vs. NICOLAS G. ALBAYDA, Sheriff II, Municipal Trial Court in Cities, Bacolod City, respondent.

FACTS

Complainant Judge Eliseo C. Geolingo charged respondent Sheriff Nicolas G. Albayda with multiple administrative offenses. The allegations included dishonesty for falsifying his daily time record by punching in and out almost simultaneously, gross incompetence for improperly serving a summons upon a defendant’s wife leading to a vacated judgment, and neglect of duty for failing to promptly implement court writs despite memoranda. Crucially, respondent was accused of grave misconduct for collecting substantial sums from litigants—specifically, P5,000 per shanty for a demolition and P15,000 for serving a writ of execution—without issuing official receipts, depositing the amounts with the clerk of court, or properly liquidating the expenses. He also failed to attend a mandated seminar.
In his Answer, respondent offered justifications, such as attributing time record issues to field work and claiming collected sums were for legitimate expenses. However, during the formal investigation before Executive Judge Ma. Lorna P. Demonteverde, respondent, appearing without counsel, made a judicial admission by unequivocally admitting to all the charges alleged in the complaint.

ISSUE

Whether respondent Sheriff Nicolas G. Albayda is administratively liable based on his judicial admission of the charges.

RULING

Yes, respondent is administratively liable and was dismissed from service. The Supreme Court adopted the findings and recommendation of the Office of the Court Administrator (OCA), which were based on respondent’s own judicial confession. A judicial admission, being a deliberate, clear, and unequivocal acknowledgment of facts during a judicial proceeding, is binding and dispenses with the need for further proof. By admitting all allegations, respondent conceded to acts constituting Dishonesty, Gross Neglect of Duty, and Grave Misconduct.
The legal logic is straightforward: admission obviates trial. His admitted acts—tampering with official time records, unauthorized exaction of large sums from litigants without court approval or proper liquidation, and dereliction of duties—directly violate the stringent ethical standards required of court personnel. These actions erode public trust in the judiciary’s integrity. The Court emphasized that a sheriff’s role is vital; any conduct falling short of the highest standards of public service, particularly acts of dishonesty and grave misconduct which are considered grave offenses, warrants the supreme penalty of dismissal to preserve the judiciary’s integrity. Consequently, respondent was dismissed with forfeiture of all benefits and with prejudice to re-employment in any government agency.