A.M. No. RTJ-08-2118; June 26, 2008
Regidor Gutierrez, complainant, vs. Judge Medel Arnaldo B. Belen, Regional Trial Court, Branch 36, Calamba, Laguna, respondent.

FACTS

Complainant Regidor Gutierrez, a postman, executed an affidavit on August 8, 2006, at the request of a State Prosecutor. The affidavit attested that on May 14, 2004, he delivered a registered mail item for then-private practitioner Medel Belen (the respondent judge) to a certain Walter Maloles, per alleged prior instructions from Belen. This mail contained a prosecutor’s resolution directing Belen to pay a filing fee, and its non-payment led to a case’s dismissal. On August 16, 2006, the judge’s brother and another individual presented Gutierrez with a “Clarificatory Affidavit” containing a different version of the delivery. After consulting his postmaster and refusing to sign, Gutierrez received a phone call from respondent Judge Belen.
Gutierrez alleged that during this call, Judge Belen was angry, uttered the invective “Punyeta ka,” and threatened to file a case against him. This prompted the administrative complaint for Unbecoming Conduct and/or Harassment. Judge Belen, in his defense, admitted calling Gutierrez but only to explain that he did not know him and never authorized mail delivery to Maloles, and to request the clarificatory affidavit. He denied using any invective or making threats, a version supported by affidavits from court sheriffs. Gutierrez countered that the insistence on the new affidavit was coercive and aimed at inducing perjury.

ISSUE

Whether respondent Judge Medel Arnaldo B. Belen is administratively liable for Unbecoming Conduct and/or Harassment based on the alleged phone call incident.

RULING

The Supreme Court DISMISSED the administrative complaint for lack of merit. The Court emphasized that in administrative proceedings, the burden of proof rests on the complainant, who must establish the charges by substantial evidence—that quantum of relevant evidence which a reasonable mind might accept as adequate to support a conclusion. The presumption that a respondent has regularly performed official duties prevails unless overcome by such substantial evidence.
Applying this standard, the Court found that complainant Gutierrez failed to present substantial evidence to corroborate his claim that Judge Belen employed duress, harassment, or uttered invectives during the phone call. The complaint relied primarily on Gutierrez’s own assertions, which were squarely contradicted by Judge Belen’s denial and the supporting affidavits. Charges based on mere allegation, conjecture, or speculation cannot be given credence. The Court held it will not hesitate to discipline erring members of the judiciary, but it equally has a duty to protect them from unfounded suits that lack evidentiary support. Since the evidence was insufficient to overcome the presumption of regularity, no administrative sanction could be imposed.