Case Digest (A.M. No. P-05-2058)
Facts:
The case involves Gitanjali M. Bondoc, the complainant, who is a Clerk of Court V at the Regional Trial Court, Branch 12 in Manila, and Luciano T. Bulosan, the respondent, who serves as a Legal Researcher in the same court. The events leading to the complaint occurred on January 18, 2005, around 9:00 a.m., when a heated argument erupted between Bondoc and Bulosan regarding Bulosan's Daily Time Record (DTR). During the confrontation, Bulosan allegedly became enraged, stood up with clenched fists, and threatened Bondoc with the words, "Anong gusto mong mangyari?" This incident caused Bondoc to tremble in fear, as she had previously been threatened by Bulosan. Ma. Teresa Mckay, a court interpreter, intervened to protect Bondoc, but Bulosan responded aggressively, challenging Mckay as well. Following the altercation, Bondoc sought assistance from security guards and reported the incident to the barangay, while Bulosan approached Judge Arranz to discuss the matter.
... Case Digest (A.M. No. P-05-2058)
Facts:
Parties Involved:
- Complainant: Gitanjali M. Bondoc, Clerk of Court V, Regional Trial Court (RTC), Branch 12, Manila.
- Respondent: Luciano T. Bulosan, Legal Researcher, RTC, Branch 12, Manila.
Incident Overview:
The complaint arose from a workplace altercation on January 18, 2005, between the complainant and respondent. The dispute centered on the respondent's Daily Time Record (DTR).
Specific Allegations by Complainant:
- Respondent became angry during an argument about his DTR.
- He stood up with clenched fists, charged towards the complainant, and threatened her by saying, "Anong gusto mong mangyari?" ("What do you want to happen?").
- Complainant trembled in fear, recalling a previous threat from the respondent.
- Ma. Teresa Mckay, a court interpreter, intervened to protect the complainant.
- Respondent also threatened Mckay by saying, "Isa ka pa!" ("You’re next!").
- Complainant reported the incident to the barangay, while respondent went to Judge Arranz.
Defense by Respondent:
- Respondent claimed he was surprised when the complainant accused him of anomalies, including not punching his own time card.
- He admitted losing his temper and pointing his finger at the complainant but denied any physical aggression.
- He argued that the complainant’s unfounded accusations were made in front of colleagues, damaging his reputation.
- He stated that the incident was investigated by Judge Arranz and that the parties had agreed to settle amicably.
Withdrawal of Complaint:
On February 2, 2005, the complainant withdrew her complaint, stating that they had resolved their differences.
Office of the Court Administrator (OCA) Evaluation:
The OCA found that the respondent’s behavior was unbecoming of a court employee and recommended that he be admonished. However, the OCA also noted that the complainant’s conduct was equally reprehensible.
Issue:
- Whether the respondent’s actions constitute conduct unbecoming a court employee.
- Whether the withdrawal of the complaint by the complainant affects the administrative liability of the respondent.
- Whether the complainant’s behavior warrants administrative sanction.
- Whether Ma. Teresa Mckay, who intervened in the altercation, should be disciplined for executing an untruthful affidavit.
Ruling:
- Dismissal of Complaint Against Respondent: The complaint against Luciano T. Bulosan was dismissed for lack of merit.
- Admonishment of Complainant: Gitanjali M. Bondoc was admonished to be more circumspect in dealing with her subordinates, with a warning against future misconduct.
- Show Cause Order for Mckay: Ma. Teresa Mckay was directed to show cause why she should not be disciplined for executing an untruthful affidavit.
Ratio:
- Conduct Unbecoming a Court Employee: While the respondent’s behavior was inappropriate, the evidence was insufficient to establish misconduct warranting disciplinary action.
- Effect of Withdrawal of Complaint: The withdrawal of the complaint does not absolve the respondent of liability in administrative proceedings, as the purpose is to protect public service and uphold the integrity of the judiciary.
- Complainant’s Behavior: The complainant’s unfounded accusations and lack of restraint in dealing with her subordinates violated the standards of conduct expected of court personnel, warranting administrative sanction.
- False Affidavit: The Court emphasized the importance of truthfulness in affidavits and initiated disciplinary proceedings against Mckay for her untruthful statement.