Case Digest (A.M. No. P-216)
Facts:
The case involves Iluminada P. Atienza as the complainant and Angelita L. Perez as the respondent. The events leading to the complaint occurred on October 12, 1973, in the office of the City Court of Manila, where both women were employed. Atienza, a cash clerk, filed a verified complaint against Perez, the personnel officer, on December 10, 1973, alleging multiple counts of misconduct. The complaint consisted of seven counts, but the Court, in its resolution dated July 9, 1974, found Perez's explanations satisfactory for six of the counts, leading to their dismissal. However, the Court ordered that the charge of grave misconduct and discourtesy during official duty be referred to the executive judge of the city court for further investigation. This investigation was conducted by Judge Alejandro Galang, Jr. in August 1974, as the executive judge, Antonio M. Consing, inhibited himself due to a petition from Atienza. During the investigation, both parties and their witnesse...
Case Digest (A.M. No. P-216)
Facts:
Parties Involved:
- Complainant: Mrs. Iluminada P. Atienza, cash clerk in the city court of Manila.
- Respondent: Mrs. Angelita L. Perez, personnel officer of the same court.
Nature of the Complaint:
- Complainant filed a verified complaint on December 10, 1973, against respondent, alleging seven counts of misconduct.
- The Court dismissed six counts on July 9, 1974, finding respondent's explanations satisfactory.
- The remaining charge of grave misconduct and discourtesy in the course of official duty was referred to the city court's executive judge for investigation.
Incident Leading to the Complaint:
- On October 12, 1973, an altercation occurred between complainant and respondent in respondent's office.
- The altercation was allegedly provoked by an anonymous letter sent to respondent, which respondent suspected was written by complainant's sister.
- Complainant confronted respondent to "disabuse" her mind of the suspicion.
Witness Testimony:
- Mr. Florencio Cabrera, a special deputy clerk of the city court, testified as a neutral witness.
- According to Cabrera, complainant approached respondent at her desk, and after an exchange of words, complainant grabbed a folder and threw it at respondent.
- Respondent threw a liquid (coke or coffee) at complainant, which also splattered on Cabrera.
- Complainant attempted to reach respondent again but was restrained by Cabrera.
Respondent's Account:
- Respondent stated that complainant grabbed folders from her hands, hurled them at her, and scattered official documents on the floor.
- Complainant also threw her high-heeled shoe at respondent, which respondent threw out of the room.
Investigating Judge's Findings:
- The investigating judge concluded that complainant provoked the incident.
- Both parties acted in a highly indecorous and censurable manner, turning the office premises into an arena and creating a public spectacle.
Issue:
- Whether respondent, as a personnel officer, violated the rules of proper decorum and behavior by participating in a public altercation with complainant.
- Whether complainant should also be held accountable for her role in provoking the incident.
Ruling:
- The Court administered a reprimand to respondent for her indecorous and censurable behavior, with a warning against repetition of the same or similar offense.
- Complainant was required to show cause within ten (10) days why no disciplinary action should be taken against her for her participation in the incident.
Ratio:
Proper Conduct in Government Service:
- Government personnel and employees are enjoined to act with self-restraint and civility at all times, even when confronted with rudeness and insolence.
- As a personnel officer, respondent is expected to set an example of proper and decorous behavior for her co-employees.
Provocation and Accountability:
- While complainant provoked the incident, respondent's participation in the altercation was equally censurable.
- Both parties acted in a manner unbecoming of government employees, violating the standards of decorum and professionalism.
Disciplinary Action:
- The Court emphasized the importance of maintaining decorum in government offices and imposed a reprimand on respondent as a disciplinary measure.
- Complainant's role in the incident warranted further investigation, and she was required to explain her actions.