G.R. No. RTJ-04-1881 & RTJ-04-1882. October 14, 2004
EVER EMPORIUM, INC. and ATTY. RACQUEL CRISOLOGO-LARA, complainants, vs. JUDGE BONIFACIO SANZ MACEDA and ATTY. EDGAR ALLAN MORANTE, respondents.

FACTS

The consolidated administrative cases arose from allegations against Executive Judge Bonifacio Sanz Maceda and Branch Clerk of Court Atty. Edgar Allan Morante of the RTC, Branch 275, Las Piñas City. Atty. Racquel Crisologo-Lara, the Clerk of Court VI, alleged that on August 15, 2001, respondent Morante requested that a specific land registration case (LRC Case No. LP-01-0070) be assigned to Judge Maceda’s sala, claiming the Judge had approved it to favor Morante’s former professor. Lara acquiesced based on this representation. The following day, she informed Judge Maceda, who claimed he only learned of it after the raffle.
Subsequent interactions led to further allegations. Lara claimed that on August 22, when she sought to be excluded from future raffles, Judge Maceda shouted at her using profane language. On August 28, Morante allegedly admitted to Lara and the Judge that he had asked his professor for a “favor” involving ₱10,000, which he later recanted, stating it was a commissioner’s fee. Lara also reported feeling threatened by the Judge’s remarks. Judge Maceda and Morante denied all allegations of irregular case assignment and misconduct.

ISSUE

Whether respondents Judge Bonifacio Sanz Maceda and Atty. Edgar Allan Morante are administratively liable for gross violation of the Code of Judicial Conduct and grave misconduct.

RULING

The Supreme Court DISMISSED the administrative complaints for lack of merit. The Court emphasized that in administrative proceedings, the burden of proof lies with the complainant, and the evidence must be substantial and credible. The allegations primarily rested on the uncorroborated testimony of Atty. Crisologo-Lara, which was contradicted by the consistent denials of both respondents and the supporting testimonies of several court employees from Branch 275. The Investigating Justice of the Court of Appeals found Lara’s testimony lacking in credibility and noted material inconsistencies.
The Court ruled that charges based on mere suspicion, conjecture, or unsubstantiated claims cannot prevail. There was no clear and convincing evidence to prove that Judge Maceda consented to the irregular assignment of the case or engaged in misconduct prejudicial to the administration of justice. Similarly, the claim against Morante regarding the ₱10,000 was not sufficiently proven. Administrative liability must be established by competent evidence, not speculation. Consequently, the complaints failed to meet the required quantum of proof.