A.M. No. RTJ-06-2013, August 4, 2006
Leonardo L. Rivera, Complainant, vs. Judge Bernabe B. Mendoza, Clerk of Court VI Jonathan Floro D. Dela Cruz and Sheriff IV Rizalde V. Severino, all of the Regional Trial Court of Roxas, Isabela, Branch 23, Respondents.

FACTS

Complainant Leonardo L. Rivera filed an administrative complaint for Manifest Bias and Partiality against respondents Judge Bernabe B. Mendoza, Clerk of Court Jonathan Floro D. Dela Cruz, and Sheriff Rizalde V. Severino. The complaint stemmed from Civil Case No. 23-569, involving Rivera and Dolores Ll. Querubin. Rivera alleged that Judge Mendoza issued a writ of execution despite the absence of a final and executory judgment and demonstrated bias in favor of Querubin, an Australian citizen. The Court Administrator initially informed Rivera that his complaint was insufficient for failing to clearly state the acts constituting the alleged violations and for not being written in a clear, simple, and concise manner as required by procedural rules.
In response, Rivera merely reiterated that the respondents did not give credence to Querubin’s nationality and requested the Supreme Court to order the partition of the subject property. The Office of the Court Administrator (OCA) subsequently noted that the complaint failed to comply with the formal requirements and consisted of bare allegations without supporting evidence. The OCA found no necessity for the respondents to comment and recommended the dismissal of the administrative case.

ISSUE

Whether the administrative complaint against the respondents should be dismissed for failure to comply with procedural requirements and for lack of merit.

RULING

The Supreme Court dismissed the complaint for lack of merit. The legal logic rests on strict adherence to procedural rules governing administrative complaints and the burden of proof incumbent upon the complainant. Section 1, Rule 140 of the Rules of Court mandates that complaints against judges must be verified, clearly and concisely state the acts or omissions constituting the violation, and be supported by affidavits or documents. Similarly, the Uniform Rules on Administrative Cases in the Civil Service require complaints against court employees to be written systematically to apprise the respondents of the charges.
The Court found that Rivera’s complaint failed to meet these fundamental requirements. His allegations of bias—based on the judge’s purported failure to consider Querubin’s nationality and the issuance of a writ of execution—were not substantiated with specific facts or evidence. He did not demonstrate how the nationality was relevant or prove the status of the civil case. Moreover, the complaint contained no averments whatsoever regarding the specific infractions of the clerk of court and the sheriff. In administrative proceedings, the burden of proof lies with the complainant, and bare allegations cannot overcome the presumption of regularity in the performance of official duties. The Court emphasized that perceived errors in judicial actions, if any, should be corrected through appropriate judicial remedies like a motion for reconsideration or an appeal, not through an administrative case absent clear evidence of bad faith or malice.