A.M. No. RTJ-04-1847 ; July 21, 2004
AURELIO M. SIERRA, et al., complainants, vs. JUDGE PATERNO G. TIAMSON and BABE SAN JOSE-RAMIREZ, respondents.

FACTS

The complainants, plaintiffs in consolidated land registration and annulment cases, filed an administrative complaint against Judge Paterno G. Tiamson and Legal Researcher Babe San Jose-Ramirez of the RTC, Binangonan, Rizal. They alleged that during pre-trial, Judge Tiamson repeatedly declared in open court that the property, already titled in the oppositors’ names, could no longer be subject to registration, thereby pre-judging the case and demonstrating gross ignorance of the law, manifest partiality, and grave misconduct. They further cited instances where the judge allegedly made threatening remarks about dismissing their case if they hired new counsel and compared his handling unfavorably to another judge. Separately, they accused Ramirez of abrasive conduct, including shouting upon learning the complainants had dismissed their counsel, who was allegedly her classmate.
Judge Tiamson denied the allegations, characterizing the complaint as a disguised motion for inhibition. He subsequently inhibited himself from the cases but denied any admission of guilt, noting it was the third time complainants sought a judge’s inhibition. Ramirez also denied the accusations, stating her interactions were proper. During the administrative investigation, Judge Tiamson passed away. Complainant Aurelio Sierra, during a hearing before the investigating executive judge, stated the complainants were no longer interested in pursuing the complaint and signed a withdrawal statement.

ISSUE

Whether the respondents should be held administratively liable based on the withdrawn complaint.

RULING

The complaint is dismissed. The Court emphasized that a complainant’s desistance or withdrawal does not automatically exonerate a respondent nor divest the Court of its disciplinary authority. However, in administrative proceedings, the burden of proof rests on the complainant to substantiate allegations with substantial evidence. In the absence of contrary evidence, the presumption of regularity in the performance of official duties prevails. Grave charges require competent evidence derived from direct knowledge; they cannot be sustained by mere allegations, conjecture, or speculation.
Here, the complainants’ explicit withdrawal and refusal to present any evidence during the investigation left the allegations unproven. With no evidence to rebut the presumption of regularity, and considering the complainants’ abandonment of their own complaint, the Court had no basis to proceed. Consequently, the administrative matter was considered closed and terminated. The ruling underscores that while withdrawal does not bar investigation, the Court cannot adjudicate liability without any supporting evidence from the complainant.