A.M. No. P-93-828 November 29, 1995
Teofilo N. Pugeda, Jr., complainant, vs. Albert N. Navalta, Sheriff, respondent.

FACTS

This administrative case arose from the execution of a judgment in Civil Case No. 3337, where the Regional Trial Court ordered Traders Royal Bank (TRB) to return P500,000 to Alco Marine Ventures, Inc. Respondent Sheriff Albert Navalta, tasked with implementing the writ, levied on TRB’s personal properties valued at approximately P5,000,000. He scheduled a public auction for June 2, 1993. Prior to the auction, TRB’s legal manager, complainant Atty. Teofilo Pugeda, informed Sheriff Navalta that another branch of the RTC had issued a notice of garnishment on TRB, effectively covering any funds TRB owed to Alco Marine, and requested a halt to the sale. Navalta refused, insisting on proceeding absent a restraining order.
On the auction day, TRB offered a manager’s check for P500,000 to satisfy the judgment. Sheriff Navalta rejected the check, demanding cash. When TRB’s representatives requested a brief recess to consult with bank officials on their bidding limit, Navalta allowed only a few minutes. He then conducted the sale with haste, completing it within 10-15 minutes. The levied properties, worth P5,000,000, were sold for only P120,000 to a lone bidder, Manolito Roxas, who was not required to make immediate cash payment.

ISSUE

Whether respondent Sheriff Albert Navalta committed misconduct and oppressive behavior in the execution of the writ.

RULING

Yes, respondent Sheriff is guilty of misconduct. The Supreme Court emphasized that a sheriff possesses discretion in conducting execution sales but must exercise it judiciously and with scrupulous fairness. Navalta’s actions collectively demonstrated oppressive conduct. His refusal to accept a manager’s check from a known solvent bank was unreasonable and contrary to standard commercial and governmental practice. His insistence on proceeding with the sale despite knowledge of a garnishment order that could have satisfied the judgment showed a reckless disregard for proper procedure.
Furthermore, the circumstances of the sale itself were highly irregular. The haste with which it was conducted, effectively denying TRB a meaningful opportunity to bid to protect its interests, coupled with the gross discrepancy between the property’s value (P5M), the judgment debt (P500,000), and the winning bid (P120,000), created a strong appearance of a rigged auction to favor a specific bidder. The Court found that Navalta’s conduct fell far short of the objectivity and caution required of a sheriff, undermining public confidence in the integrity of judicial processes. He was found guilty of oppressive behavior amounting to misconduct and fined P6,000.