A.M. No. P-93-930 June 13, 1994
ANDRES MEDILO, JANEA VILLASIN, and TWENTY-FIVE CO-SIGNERS, complainants, vs. MANUEL A. ASODISEN, Legal Researcher, Regional Trial Court of San Juan, Southern Leyte, Branch 26, respondent.

FACTS

Complainants Andres Medilo (with 25 co-signers) and Janea Villasin filed administrative charges against respondent Manuel A. Asodisen, a Legal Researcher at the RTC of San Juan, Southern Leyte, Branch 26. The charges included: (1) graft and corruption, (2) non-payment of debts, (3) conduct unbecoming a public official, and (4) malicious filing of cases. The charges stemmed from separate letters dated January 27, 1993, and February 23, 1993, addressed to the Court Administrator. The case was referred for investigation to Executive Judge Leandro T. Loyao, Jr., who designated Clerk of Court Roman T. Galdo as commissioner. The investigation revealed the following factual antecedents for each charge: On graft and corruption, Angelito Crayo and Leo Veloso alleged respondent demanded money for favorable outcomes in their criminal cases, but both were acquitted without complying. On non-payment of debts, Janea Villasin presented a decision in her favor from an unlawful detainer case against respondent; Erlinda Gabrillos claimed unpaid expenses; and Melecio de la Peña and Jaime Custodio alleged debts of P1,000 and P200, respectively. On conduct unbecoming, respondent was implicated in criminal investigations for illegal possession of firearms, violation of the Anti-Fencing Law, and grave oral defamation. On malicious filing, respondent filed cases against Arlene Rosal, Prosecutor Andres G. Yu, Jr., his sister Lucrecia Asodisen-Calungsod, and Vice-Mayor Francisco H. Casera. The investigating judge found most charges lacking substantial evidence, except for respondent’s failure to promptly settle his debt to Janea Villasin.

ISSUE

Whether respondent Manuel A. Asodisen should be held administratively liable for the charges of graft and corruption, non-payment of debts, conduct unbecoming a public official, and malicious filing of cases.

RULING

The Court dismissed the administrative complaints for insufficiency of evidence but reprimanded respondent for his failure to observe good conduct in his dealings with the public, particularly in the payment of just debts. The Court agreed with the investigating judge’s findings: On graft and corruption, the evidence was unreliable (Crayo’s testimony was influenced, Veloso did not testify, and the Ombudsman had dismissed related criminal aspects). On non-payment of debts, only the debt to Janea Villasin was substantiated; other claims were unproven or afterthoughts. On conduct unbecoming, the criminal cases were either dismissed or pending, and no administrative implications were substantiated. On malicious filing, malice could not be ascertained due to pending appeals or lack of evidence, and some cases involved personal or family disputes. However, the Court emphasized that public officers must act with integrity and responsibility. Respondent’s deliberate non-payment of a judgment debt and involvement in numerous controversies reflected poorly on his conduct as a court employee. Thus, while absolved of the specific charges, he was reprimanded and warned that future similar conduct would be dealt with more severely.