Facts:

The case before the Supreme Court of the Philippines involves a complaint lodged by Maria Raquel R. Bajar, Records Officer III in the Archives Section of the Office of the Clerk of Court in the Regional Trial Court (RTC) of Manila, against Victoriano P. Baterisna, Records Officer II in the same office. The events leading to the case unfolded on June 30, 2003, when the complainant and another employee, Joel Loja, attempted to enter the Bodega room of the Archives, which was reported to be locked from within. Upon knocking, they were admitted into the room, where they found the respondent with other RTC employees. Following this event, Bajar issued a memorandum to Baterisna reminding him that the Bodega was for official use and should be accessible during office hours. However, Baterisna refused to acknowledge receipt of the memorandum, which initiated a series of confrontations.

Later that same afternoon, Baterisna confronted Bajar in her office, berating her in front of her sta

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Facts:

Background of the Case

• The case involves a Complaint-Affidavit filed by Maria Raquel R. Bajar, Records Officer III of the Office of the Clerk of Court, RTC Manila, against Victoriano P. Baterisna, Records Officer II of the same office.
• The charges arose from alleged insubordination, disrespect, and conduct unbecoming of a judicial officer.

Chronology of Events

• On June 30, 2003, at around 1:30 p.m.:
• Complainant Maria Raquel R. Bajar, together with Mr. Joel Loja, proceeded to the Bodega room of the Archives and Notarial Section to address a concern that the room was locked from the inside.
• After persistent knocking, the door was opened revealing respondent Victoriano P. Baterisna in the company of other employees.
• In response, the complainant issued a memorandum to remind the respondent that the Bodega is designated for official use and must remain open during office hours.
• The respondent refused to acknowledge or receive the memorandum.
• Later on June 30, 2003:
• The respondent visited the complainant’s office accompanied by other staff.
• In this encounter, he loudly berated the complainant with statements such as “Wala kang karapatang mag-issue ng memo!” and further commented on her qualifications and personal attributes, questioning her right and capacity to manage the personnel.
• On the morning of July 1, 2003:
• Both parties were summoned to the Office of the Clerk of Court in the presence of Atty. Buendia.
• During the meeting, the respondent continued his verbal attack, badmouthing the complainant by further denying her authority and making disparaging remarks about her competence and personal integrity.
• The respondent warned that he would take necessary actions against the complainant if she did not withdraw her memorandum.
• Subsequent developments:
• The respondent sent a letter to the complainant denying misuse of the room and accused her of using it for personal purposes such as “physical fitness and beauty.”
• Although a criminal complaint for libel and grave slander had been initially filed by the complainant, she later desisted from pursuing it, leading to its dismissal, but subsequently continued with the administrative case.

Supporting Evidence and Testimonies

• Testimonies:
• Rico Marabut, Process Server of the OCC-RTC Manila, testified that he served the memorandum to the respondent, who remarked dismissively about the complainant’s conduct.
• Jerlyn Balbas of the Archives Section confirmed that the respondent confronted the complainant in a loud and high-pitched manner.
• Respondent’s Explanation:
• The respondent admitted that the incident occurred after he had been engaged in other official activities (raffle of cases and a late lunch).
• He claimed that his behavior was a result of a sudden outburst and contended that the complainant distorted his words due to personal bias.
• He also attempted to downplay the severity by stating that the misunderstanding was personal in nature and not related to their official duties.

Findings of the Office of the Court Administrator (OCA)

• The OCA found that the respondent did not successfully dispute the charge against him.
• It was determined that his unsavory and discourteous remarks—made in front of other court employees and notably in the presence of the Clerk of Court—were not only disrespectful but also constituted conduct unbecoming a judicial officer.
• The OCA noted that such conduct affected public service by lowering the standards of professionalism expected in the judiciary.

Recommended Sanctions by the OCA

• The OCA recommended that the administrative case be re-docketed as a regular administrative matter.
• The recommended penalty was suspension for one month and one day for gross discourtesy in the conduct of official duty.
• A stern warning was also issued that similar misconduct in the future would result in harsher sanctions.

Issue:

• Whether the respondent’s behavior, as evidenced by his unsavory and discourteous remarks, amounted to gross discourtesy in the performance of official duties.
• Whether his conduct violated the Code of Conduct and Ethical Standards for Public Officers and Employees and, by extension, the principles of propriety and decorum required of judicial employees.
• Whether the withdrawal or desistance of the complainant from the criminal complaint could bar the continuation of the administrative proceedings against the respondent.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)