Facts:

In the case of Judge Rene B. Baculi vs. Clemente U. Ugale, dated October 30, 2009, the complainant, Judge Rene Baculi, who served as the presiding judge of the Municipal Trial Court in Cities, Branch 1, Tuguegarao City, Cagayan, filed a Letter-Complaint against the respondent, Clemente U. Ugale, an Interpreter II of the same court. The complaint, submitted on February 11, 2008, charged Ugale with incompetence, habitual drunkenness, and loafing. The judge previously issued several memoranda to the respondent, starting from October 9, 2007, regarding Ugale's unauthorized absences from work, which led to disruptions in his responsibilities as a court interpreter. Furthermore, on February 4, 2008, Judge Baculi expressed concern about Ugale's incapacity to properly perform his duties, particularly during court trials, as noted by Atty. Antonio Laggui. Despite these warnings, Ugale continued to disregard the issues, leading to the administrative complaint. In his defense, Ugal

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Facts:

Filing of the Complaint

• On February 11, 2008, Judge Rene B. Baculi, presiding judge of the Municipal Trial Court in Cities, Branch 1, Tuguegarao City, filed the administrative complaint against Clemente U. Ugale, Interpreter II of the same court.
• The complaint charged the respondent with three counts: Incompetence, Habitual Drunkenness, and Loafing.

Prior Administrative Reminders and Memoranda

• On October 9, 2007, Judge Baculi issued a memorandum reminding the respondent of his habitual absences from the office, which impaired his duty as a court interpreter.
• On February 4, 2008, two separate memoranda were issued:
• One memorandum informed Ugale of a complaint made by Atty. Antonio Laggui regarding his inability to correctly interpret the vernacular dialect into English during court hearings.
• The other memorandum admonished the respondent for his habitual drunkenness during office hours.
• In all instances, Judge Baculi ordered the respondent to explain the charges against him and why sanctions should not be imposed, but the respondent ignored these directives.

Respondent’s Defense and Explanation

• In his Comment dated May 12, 2008, Ugale explained that he had sustained broken legs in a vehicular accident in February 2003 and that recurring pains in January and February 2008 worsened due to cold weather.
• He claimed that his occasional drinking was a measure to alleviate the severe pains from his injuries, which he alleged affected his performance and interpretation ability.
• He further stated that these health issues compelled him to take leave starting February 2008 and prompted him to file for early retirement, though he admitted failing to inform the judge personally.

Administrative Proceedings and the Involvement of the OCA

• The Office of the Court Administrator (OCA) investigated the matter and recommended that Ugale be held liable for all three charges, suggesting an eight (8) month suspension.
• Noting Ugale’s repeated disregard for his duties and the direct impact of his actions on the reputation of the court and the efficiency of judicial proceedings, the administrative process moved forward.

Discussion on the Nature of the Offenses and Penalty Determination

• The court reiterated the heavy burden on judicial personnel to uphold high ethical standards, stressing that any indication of negligence or impropriety in public office must be met with corrective sanctions.
• In analyzing the penalty, the court considered:
• The severity of the charge of Incompetence, deemed the most serious offense among the three.
• That Habitual Drunkenness and Loafing, though also punishable, were regarded as aggravating circumstances.
• Regulatory guidelines from the Revised Uniform Rules on Administrative Cases in the Civil Service, which provided the framework for classifying the offenses and determining the penalty range.

Final Sanction Decision

• Instead of imposing suspension, the court opted for a monetary penalty given that the respondent had filed for early retirement, which allowed the sanction to be rendered in the form of a fine deductible from his retirement benefits.
• The fine imposed amounted to the equivalent of eight (8) months’ salary, reflecting the serious nature of the offenses and the repeated disregard for office responsibilities.

Issue:

Whether the acts committed by Clemente Ugale constituted Incompetence, Habitual Drunkenness, and Loafing as charged by Judge Baculi.

• Examination of Ugale’s failure to perform his duties as a court interpreter and his repeated absences during office hours.
• Consideration of his pattern of behavior despite multiple reminders and directives.

Whether the respondent’s explanation and defense—invoking injury, recurring pain, and the subsequent need for alcohol as a palliative measure—sufficiently justified his conduct.

• Evaluation of the absence of medical documentation to support his health claims.
• Assessment of whether his actions, even if motivated by pain, corrupted the integrity of his office.

Whether the penalty, initially recommended as an eight (8) month suspension, should be converted into a fine refundable from his retirement benefits due to his pending application for early retirement.

• Determination of the appropriate disciplinary sanction considering both the gravity of the offenses and the mitigating factor of it being his first offense.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)