Case Digest (A.M. No. 05-7-458-RTC)
Facts:
In an undated letter, a Concerned Citizen from Morong, Rizal, lodged a complaint against Sheriff Sales T. Bisnar, who serves in the Regional Trial Court, Branch 78, of Morong, Rizal. The complainant accused Sheriff Bisnar of engaging in conduct unbecoming of a court employee, specifically alleging that he frequently participated in and placed bets at cockfights, sometimes during official working hours. In response to the allegations, Sheriff Bisnar submitted a comment on March 30, 2005, where he acknowledged attending cockfights but denied doing so during office hours. Following this, the Office of the Court Administrator (OCA) prepared an Agenda Report dated July 21, 2005, which recommended that Sheriff Bisnar be reminded to exercise greater caution in his actions, particularly regarding activities that could negatively impact the judiciary's reputation. The OCA emphasized that the Code of Conduct for Court Personnel mandates that court employees must uphold the honor an...
Case Digest (A.M. No. 05-7-458-RTC)
Facts:
- Complaint Filed: An anonymous complaint was filed by a Concerned Citizen of Morong, Rizal, against Sheriff Sales T. Bisnar of the Regional Trial Court (RTC), Branch 78, Morong, Rizal.
- Allegations: The complainant alleged that Sheriff Bisnar was often seen participating in and betting on cockfights, sometimes during office hours.
- Respondent's Defense: In his comment dated March 30, 2005, Sheriff Bisnar admitted attending cockfights but denied doing so during office hours.
- OCA Recommendation: The Office of the Court Administrator (OCA), in its Agenda Report dated July 21, 2005, recommended that Sheriff Bisnar be reminded to be more circumspect in his actions, particularly those that could reflect poorly on the judiciary.
Issue:
- Whether Sheriff Bisnar's participation in cockfights, even if not during office hours, constitutes conduct unbecoming of a court employee.
- Whether such actions adversely affect the integrity and honor of the judiciary.
Ruling:
The Supreme Court found Sheriff Bisnar guilty of impropriety. While there is no specific provision in the Civil Service Rules prohibiting government employees from participating in cockfights, his presence at such events created a negative impression. The Court reprimanded Sheriff Bisnar and advised him to be more circumspect in his actions to avoid casting doubt on the integrity of the judiciary.
Ratio:
- Code of Conduct for Court Personnel: Court personnel are expected to act as sentinels of justice. Any act of impropriety on their part affects the honor and dignity of the judiciary and undermines public confidence in it.
- Conduct Above Suspicion: The conduct of judges and court personnel must not only be proper and decorous but also above suspicion. Every court employee must exemplify integrity, uprightness, and honesty.
- Public Office as Public Trust: Public officers are servants of the people, and their actions must always reflect propriety and decorum. Their behavior should inspire trust and confidence in the judiciary.
- Impact on Judiciary's Image: Even if not explicitly prohibited, actions that create a negative impression, such as participating in cockfights, can harm the judiciary's reputation.