A.M. No. P-04-1927 - Aradanas vs. Dimaclid

On October 11, 2000, around 9:00 a.m., Alicia Aradanas, accompanied by her niece Jocelyn Ilaya, visited the 5th Municipal Circuit Trial Court (MCTC) of Culasi, Antique to inquire about the status of Criminal Case No. 2847-C, in which she was a prosecution witness.

While inside the court, Aradanas observed the respondents—Catherine Dimaclid, Reggie Brigido, and Riza Pelegrino—engaged in picking up small scrabble tiles that had been strewn on the floor.

Aradanas asked Dimaclid whether the case had been scheduled for hearing. Dimaclid replied that a hearing was set for October 25, 2000, and that notices had already been mailed.

Since the prosecutor was unavailable on that date, Aradanas requested that the hearing be rescheduled to an earlier date. Dimaclid explained that scheduling of hearings was solely within the court’s purview and that staff merely executed orders.

During the discussion, Aradanas lost her temper, pointed at Dimaclid, and shouted in a local dialect, "Sin-o gid kamo dya haw?" (Who are you in this court?).

Dimaclid cautioned Aradanas against shouting, stating she would inform the judge, who would determine the proper course of action.

In response, Aradanas retorted, "Sugid to kay Judge hay!" (You tell that to the judge!) and proceeded to call Dimaclid “Gaga!” (You fool!).

Amid the heated exchange, Dimaclid uttered, "Aram gid ti mo" (You know what to do) in the local dialect, a remark that was perceived as disrespectful and discourteous.

Following the incident, the judge ordered Aradanas to show cause why she should not be punished for indirect contempt. She was, however, exonerated on March 22, 2001.

Aradanas then filed an administrative complaint on February 11, 2002, seeking sanctions against Dimaclid for insulting her and against all three respondents for allegedly playing scrabble during office hours.

On August 13, 2004, Executive Judge Sylvia Jurao of the Regional Trial Court of San Jose, Antique, who was assigned to investigate the complaint, found that Catherine Dimaclid had behaved improperly and discourteously, and recommended imposing a fine of P2,000 on her.

After reviewing the case records, the appellate court adopted Executive Judge Jurao’s recommendation with modifications regarding the penalty.

While recognizing that the behavior of court personnel has a significant bearing on public confidence in the judiciary, the court held that belligerence and impropriety have no place in government service.

Consequently, only Dimaclid was found liable for discourtesy in the performance of her official duties, whereas Brigido and Pelegrino were exonerated as they were not found to be involved in any misconduct beyond assisting Dimaclid in picking up tiles.

Whether the conduct of Catherine Dimaclid, particularly her remark "Aram gid ti mo" (You know what to do), constituted discourtesy in the course of official duties.
Whether the actions of Reggie Brigido and Riza Pelegrino, allegedly playing scrabble during office hours, amounted to misconduct or were merely incidental in assisting Dimaclid.
How the behavior of court personnel, especially in the face of provoking circumstances, should be governed to maintain the honor and integrity of the judiciary.