AM P 10 2837; (August, 2010) (Digest)
G.R. No. A.M. No. P-10-2837; August 25, 2010
PO2 Patrick Mejia Gabriel, Complainant, vs. William Jose R. Ramos, Sheriff IV, Regional Trial Court, Branch 166, Pasig City, Respondent.
FACTS
Complainant PO2 Patrick Mejia Gabriel filed an administrative complaint for Grave Misconduct against respondent Sheriff William Jose R. Ramos. The complaint alleged that on May 10, 2007, in San Teodoro, Oriental Mindoro, Ramos, conspiring with a former mayor, entered a private residence and handed two ₱500 bills to residents Adelaida and Ariel Hael to secure their votes for specific candidates in the upcoming elections. The incident was reported to the police, and a criminal case for vote-buying was filed. In his defense, Ramos admitted being in the location on that date but claimed he was there solely to buy charcoal for his livelihood. He denied any political activity, asserted financial incapacity for vote-buying, and suggested the complaint was retaliatory, filed to intimidate him from pursuing robbery and administrative cases he had lodged against several policemen, including the complainant.
ISSUE
Whether respondent Sheriff William Jose R. Ramos is administratively liable for Grave Misconduct.
RULING
The Court dismissed the complaint for lack of substantial evidence. The initial evaluation by the Office of the Court Administrator (OCA) noted a factual conflict between the sworn statements of the alleged victims and Ramos’s denial, necessitating a formal investigation to ascertain the truth. The case was referred to the Executive Judge of the RTC, Pasig City, for investigation. During the investigation, only the respondent and his counsel appeared; the complainant failed to appear despite notice. The investigating judge found that the complainant failed to discharge the burden of proof in administrative proceedings. The evidence presented, primarily the respondent’s denial and indications that the complaint might have stemmed from a separate robbery case filed by Ramos against Gabriel, was insufficient to substantiate the serious charge of Grave Misconduct. The Court upheld the investigating judge’s recommendation, emphasizing that unsubstantiated accusations cannot prevail over the presumption of regularity in the performance of official duties. Absent clear and convincing evidence, the administrative charge must fail.