Case Digest (A.M. No. P-14-3252)
Facts:
This case involves an administrative complaint filed by Judge Juan Gabriel H. Alano against Padma L. Sahi, a Court Interpreter I at the Municipal Circuit Trial Court in Maluso, Basilan. The complaint, dated October 14, 2014, alleges multiple violations, including grave misconduct, absence without leave (AWOL), and violations of the Code of Conduct for Court Personnel and the Anti-Graft and Corrupt Practices Act. The events leading to the complaint began in late 2007 when Sahi was accused of soliciting money and gifts from litigants in exchange for favorable judgments in election protest cases pending before Judge Alano's court.
Specifically, between November and December 2007, Sahi allegedly brokered deals for cash payments ranging from P50,000 to P100,000. In December 2007, she informed Judge Alano that a protestee had offered him a brand new M-4 carbine assault rifle as a bribe. In January 2008, Sahi offered to sell Judge Alano a Russian AK-47 for P70,000, which he s...
Case Digest (A.M. No. P-14-3252)
Facts:
Complaint Filed by Judge Alano
Judge Juan Gabriel H. Alano filed an administrative complaint against Padma L. Sahi, a Court Interpreter I at the Municipal Circuit Trial Court (MCTC) of Maluso, Basilan. The complaint alleged that Sahi violated Sections 1 and 2 of Canon 1 of the Code of Conduct for Court Personnel, Section 3(a) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), and committed Grave Misconduct and Absence Without Leave (AWOL).Allegations of Solicitation and Bribery
- Sahi allegedly brokered for party litigants and solicited money and gifts in exchange for favorable decisions in election protest cases pending before Judge Alano’s court.
- Between November and December 2007, Sahi informed Judge Alano that some litigants were offering cash ranging from P50,000 to P100,000 for favorable judgments.
- In December 2007, Sahi informed Judge Alano that a protestee, Arzad, offered a brand new M-4 carbine assault rifle worth P180,000. Judge Alano feigned interest and later agreed to purchase a Russian AK-47 from Sahi for P30,000, suspecting it was part of a bribe.
- In April 2008, Sahi informed Judge Alano of Arzad’s new offer of a Honda 200R motorcycle in exchange for a favorable judgment.
- Sahi allegedly demanded P50,000 from Sawari, a protestee, for a favorable judgment and received P5,000 for Judge Alano’s alleged travel expenses to Manila.
- Abdurajak Jalil, a protestant, claimed Sahi solicited P60,000 for a printer for the court but used the money for personal gain.
- Sahi also allegedly received P50,000 and P5,000 from the Barangay Chairman of Mebak, Sumisip, Basilan, intended for Judge Alano.
AWOL Allegations
- Sahi failed to report for work for more than 30 calendar days starting June 18, 2008, without filing an official leave application.
- Judge Alano requested the Leave Section of the Office of the Court Administrator to drop Sahi from the rolls due to her AWOL status.
Sahi’s Defense
- Sahi denied soliciting money or gifts, claiming she only assisted Judge Alano in finding a firearm dealer.
- She denied receiving P5,000 from Jalil for Judge Alano’s travel expenses.
- She claimed her absences were due to illness (acute bronchitis and urinary tract infection) and that her leave applications were disapproved or ignored by Judge Alano.
Investigation and Findings
- The case was referred to Executive Judge Reynerio G. Estacio, who found Sahi guilty of brokering for litigants and soliciting money or gifts.
- Affidavits from Sawari and Jalil corroborated Sahi’s corrupt practices.
- Sahi’s defense of denial was deemed insufficient, and her failure to present witnesses weakened her case.
Issue:
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Ruling:
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Ratio:
Violation of Code of Conduct and Anti-Graft Law
- Sahi’s actions of soliciting and receiving money and gifts from litigants violated Sections 1 and 2 of Canon 1 of the Code of Conduct for Court Personnel and Section 3(a) of the Anti-Graft and Corrupt Practices Act.
- Her conduct degraded the judiciary and undermined public trust in the court system.
Grave Misconduct
- Sahi’s corrupt practices, including soliciting bribes and acting as a broker for litigants, constituted Grave Misconduct, a grave offense punishable by dismissal even for the first offense.
AWOL and Poor Performance
- Sahi’s unauthorized absences for 67 consecutive working days violated civil service rules, warranting her separation from service.
- Her prolonged absence disrupted court operations and demonstrated a lack of accountability and responsibility.
Public Accountability
- The Court emphasized that all court personnel must uphold the highest standards of integrity and accountability. Sahi’s actions were incompatible with these standards and justified her dismissal.