Case Digest (A.M. No. P-05-2014)
Facts:
The case involves Judge Orlando D. Beltran, the complainant, and Vilma C. Pagulayan, the respondent, who served as Interpreter III at the Regional Trial Court (RTC), Branch 2, Tuguegarao City, Cagayan. The complaint was filed on July 18, 2001, alleging that Pagulayan engaged in gross misconduct by demanding and receiving P20,000.00 from the plaintiffs in Civil Case No. 5383, which was decided in favor of the plaintiffs by Judge Beltran. The money was purportedly solicited for Judge Beltran in exchange for a favorable decision. Following the alleged transaction, Pagulayan handed the plaintiffs an unsigned copy of the decision. In response to the complaint, Judge Beltran and the Branch Clerk of Court, Atty. Maita Grace Deray-Israel, requested an investigation by the National Bureau of Investigation (NBI). The NBI submitted a report on August 6, 2001, recommending administrative charges against Pagulayan based on testimonies from Judge Beltran, Deray-Israel, and the plaintiffs, ...
Case Digest (A.M. No. P-05-2014)
Facts:
Background of the Case
- The case involves an administrative complaint filed by Judge Orlando D. Beltran against Vilma C. Pagulayan, an Interpreter III at the Regional Trial Court (RTC), Branch 2, Tuguegarao City, Cagayan. The complaint alleges that Pagulayan demanded and received P20,000.00 from the plaintiffs in Civil Case No. 5383, claiming it was for Judge Beltran, in exchange for a favorable decision.
Allegations
- Judge Beltran, after rendering a decision in favor of the plaintiffs, received reports that Pagulayan had demanded money from the plaintiffs, Facundo Baccay and Saturnino Acain, under the pretext that it was for the judge. Pagulayan allegedly handed the plaintiffs an unsigned copy of the decision after receiving the money.
Investigation
- Judge Beltran and the Branch Clerk of Court, Atty. Maita Grace Deray-Israel, requested the National Bureau of Investigation (NBI) to investigate the matter. The NBI recommended that Pagulayan be charged administratively for misconduct based on affidavits from Judge Beltran, Deray-Israel, and the plaintiffs.
Pagulayan’s Defense
- Pagulayan denied the allegations, claiming she did not demand or receive any money. She stated that her only involvement was referring a relative of the plaintiffs to the clerk in charge of civil cases. She expressed surprise at the charges and lamented that Judge Beltran did not confront her directly.
Procedural History
- The case was referred to the Executive Judge of RTC Tuguegarao City for investigation. However, due to conflicts of interest, the case was reassigned to Judge Virgilio M. Alameda, who found Pagulayan guilty of gross misconduct and recommended a six-month suspension. The Office of the Court Administrator (OCA) later recommended a one-year suspension.
Further Proceedings
- Pagulayan requested to present her evidence, but her counsel withdrew, and she traveled abroad. The case was reassigned to Judge Rolando R. Velasco, who also found Pagulayan guilty and recommended a one-year suspension.
Issue:
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Ruling:
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Ratio:
- Credibility of Testimony: The Court found the testimony of Facundo Baccay credible and consistent with the evidence. Pagulayan’s denial was insufficient to overcome the evidence presented against her.
- Misconduct in Public Office: Pagulayan’s actions constituted gross misconduct, which is a grave offense under Civil Service rules. Her behavior violated the standards of integrity and honesty required of public servants, especially those in the judiciary.
- Penalty: Given the gravity of the offense, the Court ruled that Pagulayan deserved the penalty of dismissal. However, since she had already retired, the Court imposed the forfeiture of her retirement benefits, except for accrued leave credits, and barred her from re-employment in any government branch or instrumentality.
Conclusion:
- The Supreme Court held Pagulayan administratively liable for gross misconduct and imposed the penalty of forfeiture of her retirement benefits, with prejudice to re-employment in the government. The decision underscores the importance of maintaining integrity and trust in the judiciary and public service.