A.M. RTJ-00-1589; September 29, 2000
Jeanet N. Manio, complainant, vs. Judge Jose Ener S. Fernando, Regional Trial Court, Branch 5, Dinalupihan, Bataan, respondent.

FACTS

Complainant Jeanet N. Manio, appointed as the judicial guardian of her minor son, charged respondent Judge Jose Ener S. Fernando with giving her “a hard time” by allegedly freezing her bank accounts, preventing her from withdrawing money to buy land. The respondent judge explained that the guardianship court, after granting the petition, had ordered Manio to post a P100,000 bond and submit regular inventories of the minor’s estate, which included substantial U.S. dollar insurance proceeds. Manio failed to post the bond, prompting the court to issue a protective order restricting withdrawals from the identified bank account without court approval to safeguard the minor’s assets.
Manio later filed motions to withdraw funds, which the judge promptly granted, authorizing withdrawals totaling US$20,000 for stated expenses. The judge imposed conditions, such as requiring submission of a sales contract, to ensure the withdrawals were proper. Manio subsequently filed a sworn letter amplifying her complaint, alleging that the judge had recommended a lawyer, solicited P35,000 for legal fees, and personally accompanied her to the bank. She later requested the dismissal of her complaint, stating it was filed out of ignorance and anger. An investigation was assigned, but Manio failed to appear at the scheduled hearings despite notice.

ISSUE

Whether respondent Judge Jose Ener S. Fernando is administratively liable for misconduct based on the allegations of the complainant.

RULING

The Supreme Court dismissed the complaint for lack of evidence. The legal logic rests on the fundamental principle that in administrative proceedings, the burden of proof lies with the complainant, and charges must be substantiated by substantial evidence. The Court found that the respondent judge’s actions were justified exercises of judicial discretion aimed at protecting the welfare and estate of the minor ward, a paramount duty in guardianship proceedings. The orders restricting withdrawals and requiring a bond and inventories were standard protective measures, not acts of harassment. The prompt granting of the motions to withdraw demonstrated judicial efficiency, not obstruction.
The serious allegations of soliciting money and unethical conduct, while grave if proven, were not corroborated. The complainant’s failure to appear and present evidence during the investigation, coupled with her subsequent withdrawal of the complaint, left the allegations unsubstantiated. Without any evidentiary basis, the Court could not hold the respondent judge administratively liable. The dismissal underscores that judges cannot be sanctioned based on unproven accusations, and their official actions, when performed in the regular exercise of jurisdiction and with due regard for their fiduciary responsibilities, enjoy the presumption of regularity.