AM RTJ 04 1854; (June, 2004) (Digest)
G.R. No. RTJ-04-1854. June 8, 2004
ANA MARIA C. MANGUERRA, Complainant, vs. JUDGE GALICANO C. ARRIESGADO, et al., Respondents.
FACTS
Complainant Ana Maria C. Manguerra filed an administrative complaint against several judges and court personnel of the Regional Trial Court of Cebu City. She charged them with Irregular Raffling of Cases, Dereliction of Duty, and Falsification in relation to Special Proceeding No. 1700-R, the intestate estate of Mariano F. Manguerra. The complainant alleged that the case was irregularly unloaded from Branch 6 and clandestinely re-raffled to Branch 23 to favor the oppositors. She argued this violated proper procedure.
The respondents, including Executive Judge Arriesgado and Branch 6 Judge Caminade, explained in their Joint Comment that the unloading and re-raffling followed an established local practice. They stated that when a judge inhibits himself, as Judge Antonio Echavez did in the Borromeo case (Special Proceeding No. 916-R), that inhibited case is assigned by regular raffle to another branch. The receiving branch then unloads a case of similar nature and status to the inhibiting judge without a separate raffle. Accordingly, Branch 6 unloaded Special Proceeding No. 1700-R to Branch 8 (Judge Echavez) in exchange for the Borromeo case.
ISSUE
Whether the respondents are administratively liable for the alleged irregularities in the raffling of Special Proceeding No. 1700-R.
RULING
The Supreme Court DISMISSED the complaint for lack of merit. In administrative proceedings, the burden of proof lies with the complainant to substantiate the allegations with substantial evidence. During the investigation by the designated Court of Appeals Justice, the complainant manifested she was no longer interested in pursuing the case, believed the respondents were not liable, and was unwilling to testify. Consequently, the allegations in the complaint remained unsubstantiated.
The Court emphasized that in the absence of competent evidence to the contrary, the presumption of regularity in the performance of official duties prevails. Charges based on mere suspicion and speculation cannot be given credence. The rules demand that for a judge or court personnel to be disciplined for grave misconduct, the evidence must be competent and derived from direct knowledge. Since the complainant failed to present any evidence to prove culpability, the charges were reduced to a mere unproven indictment. The Court, therefore, found no basis to hold the respondents administratively liable.