A.M. No. P-06-2229. January 31, 2007.
Josefina Libuit-Lewis, Complainant, vs. Loida P. Moralejo, Legal Researcher, RTC, Branch 32, Manila, Respondent.

FACTS

Complainant Josefina Libuit-Lewis filed an administrative complaint against respondent Loida P. Moralejo, a Legal Researcher at the RTC, Branch 32, Manila, for Abuse of Power, Obstruction of Justice, and Negligence concerning an appealed ejectment case. Complainant alleged that respondent intentionally failed to have the case decided promptly after all pleadings were filed in October 2004, keeping the records improperly in a cabinet. She claimed respondent repeatedly promised to bring the records to the judge but failed, and later informed her that the presiding judge, Judge Juan C. Nabong, Jr., had retired without acting on the case. Complainant further accused respondent of withholding a motion for execution and failing to remand the case records to the court of origin after a favorable decision, causing procedural setbacks.
In her Comment, respondent denied the accusations, explaining that the delay was due to circumstances beyond her control. She detailed that Judge Nabong, Jr. suffered a stroke and pneumonia, leading to his early retirement in June 2005, which left several cases, including complainant’s, undecided. Respondent asserted that case records were kept in a designated cabinet for cases submitted for decision. She further explained that the records could not be remanded immediately after the decision because the trial court was awaiting the return of notices and the resolution of an appeal to the Court of Appeals, with remittance eventually occurring in February 2006.

ISSUE

Whether respondent Loida P. Moralejo is administratively liable for Abuse of Power, Obstruction of Justice, and Negligence as alleged by complainant.

RULING

The Supreme Court DISMISSED the administrative complaint for lack of merit. The Court found that the charges were not substantiated by evidence. The investigation revealed that the delay in the disposition of complainant’s case was attributable to the health problems and subsequent retirement of Judge Nabong, Jr., not to any malfeasance by respondent. The legal logic is grounded in the presumption of regularity in the performance of official duties, which stands absent clear and convincing proof to the contrary. Complainant failed to overcome this presumption with concrete evidence showing that respondent willfully caused delay or neglected her duties. The Court emphasized that while it is vigilant in disciplining judiciary personnel, it also protects them from unfounded accusations that disrupt judicial administration. However, complainant was warned to observe more circumspection in filing administrative cases.