Facts:

The administrative matter at hand involves Judge Celso O. Baguio, presiding Judge of the Regional Trial Court (RTC) Branch 34 in Gapan City, Nueva Ecija, who filed a complaint against Jocelyn P. Lacuna, the court's Stenographer III. The complaint, dated January 25, 2013, pertained to allegations of gross incompetence by Lacuna. It was claimed that she failed to transcribe and submit the stenographic notes for the pre-trial proceedings of Criminal Case No. 14405-10 (People of the Philippines v. Jason Ondrade), which had taken place on November 16, 2012. Subsequently, the scheduled initial trial had to be reset due to her failure to perform her duties. Despite receiving an order from the judge to immediately transcribe the notes, Lacuna provided a written apology on January 28, 2013, citing the absence of the prosecution’s witness as a contributing factor to the case's postponement. Judge Baguio further highlighted that Lacuna had a prior suspension for a similar offense,

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Facts:

Background of the Complaint

• Judge Celso O. Baguio, Presiding Judge of RTC Branch 34 in Gapan City, Nueva Ecija, filed a letter-complaint against respondent Jocelyn P. Lacuna, a Stenographer III of the same court.
• The complaint arose from the resetting of the initial trial of Criminal Case No. 14405-10 (People of the Philippines v. Jason Ondrade) on January 25, 2013, due to respondent’s failure to transcribe and submit the stenographic notes of the pre-trial proceedings held on November 16, 2012.
• Judge Baguio issued an Order directing the respondent to immediately transcribe the notes and submit a written explanation as to why she should not be held administratively liable.

Respondent’s Explanation and Previous Record

• Respondent submitted a letter dated January 28, 2013, where she apologized for her oversight.
• She argued that the delay in transcription resulted not solely from her negligence but also from the absence of the prosecution’s witness on that particular day.
• It was noted that this was not her first infraction; a previous suspension for similar incompetence had been recorded in A.M. No. P-11-2933 (formerly OCA IPI No.07-2674-P).
• Despite past deficiencies, Judge Baguio recognized her almost perfect attendance and generally proper courtroom demeanor, though he noted her tendency to work independently and quietly.

Administrative Proceedings and Comments

• The Office of the Court Administrator (OCA) issued the 1st Indorsement on March 4, 2013, directing respondent to comment on the complaint.
• In her Comment dated April 15, 2013, respondent admitted to her failure to transcribe the notes on time but maintained that the omission was a mere oversight or inadvertence.
• She explained that the regular schedule—with hearings three times a week, particularly heavy on Fridays when the incident occurred—coupled with the rotational duty among three stenographers, contributed to her delay.
• The respondent stressed that her apology was not an admission of gross incompetence and highlighted her consistent attendance as evidence of her commitment to her duties.
• She requested either the dismissal of the complaint or a mitigation of the penalty if found guilty.

Administrative Investigation and Recommendation

• On September 11, 2015, the OCA recommended that the complaint be referred to the Executive Judge of the RTC of Cabanatuan City, Nueva Ecija, for further investigation and recommendation.
• The Executive Judge, in her Report and Recommendation dated March 2, 2017, found the respondent guilty of simple neglect of duty.
• The investigation revealed that although the respondent did complete the transcription before the next scheduled hearing, her performance was slow and failed to meet the prescribed twenty (20) day period for transcription.
• Taking into account her previous infraction, the twenty-one (21) years of public service, and observable improvement in her work habits, the recommended penalty was six (6) months suspension without pay for simple neglect of duty.

Summary of the Incident

• The central factual issue revolves around the respondent’s failure to transcribe and submit the stenographic notes within the required period, leading to operational delays in the court.
• The administrative proceedings examined the respondent’s workload, prior record, and mitigation factors before recommending disciplinary action.

Issue:

The sole issue presented in this case is whether or not the respondent, Jocelyn P. Lacuna, should be held administratively liable for simple neglect of duty.

• Consideration is given to whether the delays in transcribing the stenographic notes, despite later completion, constitute a breach of duty serious enough to merit suspension.
• The determination includes assessing the adequacy of the respondent’s excuse concerning heavy workload and team scheduling, against her statutory duty to promptly deliver and transcribe court records.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)