G.R. No. P-06-2218, August 15, 2006
Albert S. Dela Peña, Complainant, vs. Iluminado R. Huelma, Interpreter, MCTC, Cantilan-Carrascal, Surigao del Sur, Respondent.

FACTS

A land dispute existed between complainant Albert Dela Peña, a board member of CAMPCO, and the family of respondent Iluminado Huelma, a court interpreter. Dela Peña alleged that Huelma instigated his relatives to claim portions of a fishpond leased by CAMPCO, leading to litigation. Dela Peña further charged that Huelma, misusing court resources, facilitated the filing of criminal cases, including one for malicious mischief raffled to their own MCTC. He accused Huelma of preparing the order for a warrant of arrest and the warrant itself, then misleading Presiding Judge Jesusa Garcia-Perez into signing them despite the case falling under the Rule on Summary Procedure, which generally prohibits arrest orders. Dela Peña claimed public humiliation from his arrest.
In his defense, Huelma denied instigating the cases, asserting the land was awarded to his family by agrarian reform. Judge Perez, in her comment, assumed full responsibility for the erroneous issuance of the warrant, calling it a serious inadvertence, and denied being misled by Huelma. She had quashed the warrant upon realizing the error. The investigating executive judge found that while Huelma admitted preparing the warrant upon the judge’s order, the evidence did not prove he prepared the underlying order or acted with malicious intent.

ISSUE

Whether respondent Iluminado R. Huelma is administratively liable for Grave Misconduct and acts prejudicial to the best interest of the service.

RULING

No. The Supreme Court dismissed the complaint for lack of merit. In administrative proceedings, the burden of proof lies with the complainant, who must establish the allegations by substantial evidence—that degree of relevant evidence which a reasonable mind might accept as adequate to support a conclusion. The respondent enjoys the presumption of regularity in the performance of official duties.
The Court found Dela Peña’s accusations were based on assumptions unsupported by substantial evidence. The claim that Huelma used court time and resources for personal gain was unproven. Crucially, the presiding judge herself absolved Huelma by accepting full responsibility for the mistaken issuance of the warrant, explicitly stating she was not misled. The investigating judge’s report also indicated a lack of conclusive proof of malicious intent, noting that the bail amount set in the order contradicted the theory of personal vendetta. Consequently, the complainant failed to overcome the presumption of regularity in Huelma’s conduct, and the required quantum of proof was not met.