Case Digest (A.M. No. P-2221)
Facts:
The case involves Atty. Cipriano Abenojar as the complainant and Domingo Lopez as the respondent. The events leading to the complaint occurred on June 28, 1979, at the office of the Clerk of Court, Court of First Instance of Pangasinan, Branch IX. Abenojar approached Lopez, a clerk responsible for handling land registration cases, to inquire about the hearing location of a petition filed by Rodrigo Sapigao in Land Case No. 29, G.L.R.O. Rec. No. 9961. Lopez, after checking his records, informed Abenojar that the file was not present and might be in another branch. When Abenojar sought clarification, Lopez responded in an aggressive manner, raising his voice and dismissing Abenojar's inquiries with a curt "Period." The situation escalated when Abenojar requested Lopez's name from Deputy Sheriff Homobono Queyquep, prompting Lopez to challenge Abenojar publicly, stating, "Meet me anywhere. I am not afraid." Following this, Lopez made a threatening rema...
Case Digest (A.M. No. P-2221)
Facts:
Complainant’s Allegations:
Atty. Cipriano Abenojar filed a sworn letter-complaint against Domingo Lopez, a clerk handling land registration cases in the Court of First Instance of Pangasinan, Branch IX. Lopez was accused of arrogance, disrespectful conduct, incompetency, and abuse of authority. The incident occurred on June 28, 1979, when Abenojar inquired about the hearing location for a land registration case. Lopez initially stated the file was not in his branch, but when Abenojar asked for confirmation, Lopez responded rudely, saying, "I said it is not here ---- Period" and later challenged Abenojar with aggressive remarks, including threatening gestures.
Respondent’s Admission:
Domingo Lopez admitted in his comment-explanation that he had answered back Abenojar but later realized his fault and sought forgiveness. He apologized to Abenojar, and the latter subsequently requested the withdrawal of the complaint.
Recommendation by Deputy Court Administrators:
The Deputy Court Administrators recommended that Lopez be admonished and warned to always be courteous in dealing with the public, emphasizing that a repetition of such behavior would be dealt with more severely.
Issue:
- Whether Domingo Lopez’s behavior constituted discourtesy and arrogance unbecoming of a court employee.
- Whether the withdrawal of the complaint by the complainant absolves Lopez from disciplinary action.
- Whether the court has the authority to impose disciplinary measures despite the complainant’s desistance.
Ruling:
The Court ruled that Domingo Lopez’s conduct was indeed discourteous and unbecoming of a public officer. Despite the complainant’s withdrawal of the complaint and Lopez’s admission of fault, the Court found that such actions do not bar the imposition of disciplinary measures. Lopez was admonished and warned to always be courteous in the performance of his duties, with the caveat that any repetition of similar acts would be dealt with more severely.
Ratio:
- Discourtesy in Official Duties: Discourtesy in the performance of official duties is a valid ground for disciplinary action under civil service laws. Public officers must demonstrate courtesy and civility in their interactions with the public.
- Public Office as a Public Trust: The Constitution mandates that public officers serve with the highest degree of responsibility, integrity, loyalty, and efficiency. Lopez’s behavior violated this principle.
- Desistance Does Not Bar Disciplinary Action: The withdrawal of a complaint or the complainant’s desistance does not prevent the Court from taking disciplinary action, especially when the respondent’s guilt is admitted.
- Supervisory Power of the Court: Administrative actions cannot be made dependent on the complainant’s will, as this would undermine the Court’s authority to discipline erring personnel.