G.R. No. 254328. December 02, 2021
ANDREW N. BAYSA, PETITIONER, VS. MARIETTA V. SANTOS, RESPONDENT.

FACTS

Petitioner Andrew N. Baysa was the Provincial Adjudicator of the DARAB in Malolos City. On June 30, 2003, he rendered a Decision in DARAB Case No. R-03-02-990799 in favor of tenants Perfecto Cabral and Loreda G. Vda. de Almario against Spouses Constantino and Zenaida Pascual. The decision became final and executory. During execution proceedings, a motion for a writ of demolition was filed by the tenants. Respondent Marietta V. Santos, who was not a party to the DARAB case, began receiving copies of pleadings related to the motion. A writ of demolition was subsequently issued and served on Santos, covering a building on her own property. Santos filed a motion with the DARAB to desist from disturbing her property rights, arguing she was not a party to the case and had a pending action before the RTC. Baysa denied her motion and motion for reconsideration. Santos then filed an administrative complaint against Baysa before the Office of the Ombudsman for unjust judgment and erroneous issuance of the writ. The Ombudsman found Baysa guilty of Simple Misconduct and suspended him for three months without pay, ruling he acted beyond his authority and deprived Santos of due process. The Court of Appeals affirmed the Ombudsman’s decision. Baysa filed the present petition.

ISSUE

Whether the Court of Appeals erred in affirming the finding that petitioner Andrew N. Baysa is guilty of Simple Misconduct for issuing orders leading to the demolition of respondent Marietta V. Santos’s property without due process.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision and Resolution of the Court of Appeals. The Court held that petitioner Andrew N. Baysa committed Simple Misconduct. He disregarded established rules and violated respondent Marietta V. Santos’s right to due process by enforcing a judgment against her when she was never a party to the DARAB case. The records showed Santos was not mentioned in the original petition, never impleaded, and her property was distinct from the land subject of the agrarian dispute. Baysa erroneously considered her a successor-in-interest of the Spouses Pascual without evidence and failed to afford her a hearing on her motion, instead adopting unsupported allegations from the tenants. His actions constituted a transgression of a definite rule of action and a dereliction of duty. The penalty of three months suspension without pay was appropriate. The Court emphasized that administrative liability remains even if the act is done in the course of official duties, and the Ombudsman’s findings, supported by substantial evidence, are accorded respect.