G.R. No. P-04-1812. May 28, 2004
RELIWAYS INC., represented by AURELIO P. VENDIVEL, JR., complainant, vs. LAMBERTO P. GRANTOZA, Process Server, MeTC, Br. 62, Makati City, respondent.

FACTS

Complainant Reliways Inc., through Aurelio Vendivel, filed an administrative complaint against respondent Lamberto Grantoza, a Process Server at the MeTC of Makati, for conduct unbecoming a court employee due to his failure to pay just debts. It was alleged that Grantoza obtained two loans from Reliways in April and May 2001 totaling ₱11,500.00, executing corresponding promissory notes. Despite oral and written demands, he refused payment, with the obligation ballooning to ₱19,427.05 by May 2003. Vendivel also contended that Reliways was compelled to grant the loan because it had a pending criminal case in the court where Grantoza was stationed.
In his Comment, Grantoza admitted the loans but denied any intention to evade payment, claiming he had made partial payments. He denied knowledge of Reliways’ pending case and asserted that the loan was offered through the Clerk of Court’s office. Vendivel, in a Reply, denied any partial payment and reiterated that personal demands were made, maintaining that they knew each other due to the pending case.

ISSUE

Whether respondent Lamberto Grantoza is administratively liable for willful failure to pay a just debt, constituting conduct unbecoming a court employee.

RULING

Yes, respondent is administratively liable. The Revised Administrative Code of 1987, specifically Section 46(b)(22), Title I, Book V, provides that willful failure to pay just debts is a ground for disciplinary action. A “just debt” under the implementing Omnibus Rules refers to a claim whose existence and justness are admitted by the debtor. Grantoza explicitly admitted the indebtedness in his Comment, thereby satisfying this definition. His claim of partial payment remained unsupported by evidence.
The Court emphasized that the penalty addresses the unbecoming conduct of a public official, not merely his private affairs. Under the Omnibus Rules, willful failure to pay just debts is classified as a light offense. For a first offense, the prescribed penalty is reprimand. Considering Grantoza’s employment since 1979 and this being his first infraction, the Court imposed a reprimand, modifying the OCA’s recommendation for a severe reprimand. The Court, however, gave no credence to Vendivel’s unsubstantiated claim that Reliways was forced to lend money due to its pending case, noting that a mere process server could not have exerted such pressure. Respondent was reprimanded with a warning that repetition would be dealt with more severely.