Title
Concerned Citizens vs. Ruth Tanglao Suareza Holguin, Utility Worker 1, Office of the Clerk of Court, Regional Trial Court, Angeles City, Pampanga
Case
A.M. No. P-18-3843 (Formerly OCA IPI No. 16-4612-P
Decision Date
Jun 25, 2018
A utility worker faced multiple allegations, including neglect of duty and immorality, but was found guilty only of failing to secure travel authorities for 13 foreign trips, resulting in a 30-day suspension. Other charges were dismissed due to insufficient evidence.

Case Digest (A.M. No. P-18-3843 [Formerly OCA IPI No. 16-4612-P)
Expanded Legal Reasoning Model

Facts:

  • Filing of the Complaint
    • Concerned citizens anonymously filed a complaint on April 23, 2013 against Ms. Ruth Tanglao Suarez-Holguin, a Utility Worker 1 at the Office of the Clerk of Court, Regional Trial Court, Angeles City, Pampanga.
    • The complaint alleged various infractions based on misconduct, immorality, and violation of Paragraph B (4) of OCA Circular No. 49-2003.
  • Allegations Contained in the Complaint
    • Payment of another person to perform her duties, implying neglect of official responsibilities.
    • Violation of the prescribed dress code as established by the office regulations.
    • Unauthorized travel abroad—traveling without securing the required travel authority.
    • Use of official working hours to attend to personal business, specifically money lending and selling imported items, allegedly using office time.
    • Immorality by allegedly disclosing sexual relations with several male foreigners during her travels.
    • Using Supreme Court stickers on her public utility vehicles purportedly to evade traffic citations.
  • Respondent’s Explanation and Defense
    • Suarez-Holguin stated that her failure to perform duties for a period was due to undergoing two laminectomy surgeries for severe back pain, and that she relied on the assistance of other utility workers during that time.
    • She denied any violation of the prescribed dress code, maintaining that her uniform was neither altered nor manipulated during her 19 years of service.
    • She refuted the allegation of using official time for personal business by clarifying that the items sold were either pasalubong or procured at the request of co-employees during her lawful travels.
    • Concerning the allegation of immorality, she explained that her trips abroad were undertaken exclusively with her husband, not with multiple foreign men.
    • On the use of Supreme Court stickers, she admitted that a sticker was affixed on her Honda sedan but asserted that it was solely for identification purposes when entering or exiting the City Hall premises, not a means to circumvent traffic laws.
    • With respect to travel authorities, while she was able to produce valid travel documents for two of her trips (to Vietnam and the United States), she failed to submit the mandatory travel authorities for the remaining foreign trips.
  • OCA’s Investigation, Findings, and Recommendation
    • The Office of the Court Administrator (OCA) conducted an investigation evidenced by a report dated February 20, 2018.
    • The OCA recommended the dismissal of charges related to immorality and other allegations (such as neglect of duty, dress code violation, misuse of official time, and use of Supreme Court stickers) due to insufficient substantial evidence.
    • However, the OCA found sufficient basis to discipline her for failing to secure travel authorities for thirteen (13) foreign trips spanning from June 18, 2010 to September 21, 2013 and, thus, recommended disciplinary action under Paragraph B (4) of OCA Circular No. 49-2003.
    • The report noted that although her absences from work during those trips were covered by approved leave applications, her non-compliance with the travel authority requirement remained a violation.
  • Documentary and Evidentiary Support
    • Social media postings, including photographs of Suarez-Holguin in a bikini, were submitted but deemed insufficient to prove the charge of immorality due to the lack of concrete evidence linking the images to any sexual misconduct.
    • Certificates and travel records from both the Bureau of Immigration and the Office of Administrative Services corroborated that she traveled abroad on numerous occasions without the corresponding travel authorizations.

Issues:

  • Whether or not the administrative complaints against Ms. Ruth Tanglao Suarez-Holguin are supported by substantial evidence.
    • This includes the allegations of neglect of duty, violation of the prescribed dress code, misuse of official time for personal business, immorality, and the use of Supreme Court stickers to evade traffic citations.
  • Whether failure to secure a travel authority for thirteen (13) foreign trips within a span of three (3) years constitutes a sufficient ground to hold her administratively liable under OCA Circular No. 49-2003.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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