Facts:

This case involves an administrative complaint filed by Atty. Roel O. Paras against Myrna F. Lofranco, a Clerk III at the Regional Trial Court (RTC), Branch 20, Digos, Davao del Sur. The complaint was lodged on March 12, 1997, alleging discourtesy and conduct unbecoming of a court employee. Atty. Paras, who was serving as the Vice-President of the Integrated Bar of the Philippines (IBP) Davao del Sur Chapter, approached Lofranco on February 28, 1997, to facilitate the withdrawal of a cash bail bond on behalf of his client. During this interaction, Lofranco allegedly responded to Paras in a disrespectful and sarcastic manner, stating, "Ambot lang kay dili ra man ikaw ang tig-withdraw diri, sa Lunes na lang ni," which translates to "I do not know because you are not the only one withdrawing here, just come back on Monday."

The situation escalated when Lofranco questioned the adequacy of the documents presented by Paras, leading to a heated exchange where ...

Facts:

Background of the Case

• Atty. Roel O. Paras, a practicing lawyer and Vice-President of the Integrated Bar of the Philippines (IBP), Davao del Sur Chapter, filed an administrative complaint against Myrna F. Lofranco, Clerk III of the Regional Trial Court (RTC), Branch 20, Digos, Davao del Sur, for discourtesy and conduct unbecoming a court employee.

Incident on February 28, 1997

• Atty. Paras approached Lofranco to facilitate the withdrawal of a cash bail bond on behalf of his client. He presented the court order and inquired if the withdrawal could be processed with only one signatory present, asking if the bank account was joint.
• Lofranco responded sarcastically, stating, "Ambot lang kay dili ra man ikaw ang tig-withdraw diri, sa Lunes na lang ni" ("I do not know because you are not the only one withdrawing here, just come back on Monday").
• Atty. Paras complied with Lofranco's request to reproduce the receipts. Upon returning, Lofranco remarked, "Unsaon man pag-received ana nga usa ra ma na ka kopya, dapat abogado ka kahibalo ka sa requirements" ("How could we receive that when that is only a single copy? You are a lawyer and you are supposed to know the requirements").
• Atty. Paras felt insulted and told Lofranco, "You are not supposed to talk like that to a lawyer." The exchange escalated, with both parties calling each other "crazy."

Additional Allegations

• Atty. Paras claimed that Lofranco was not the person in charge of the withdrawal of bank deposits but one of her officemates, Luzminda Baba, who was present at the time.
• He also alleged that Lofranco had a history of unethical and arrogant behavior, including being featured in a local newspaper for her conduct.

Respondent’s Defense

• Lofranco countered that Atty. Paras appeared drunk and treated her disrespectfully. She claimed that she politely informed him that the withdrawal could not be processed that day due to the absence of required signatories.
• She denied calling Atty. Paras "crazy" and stated that she only responded to his arrogant behavior.

Testimonies and Evidence

• Luzminda Baba testified that there was no Special Power of Attorney (SPA) attached to the case records, which was required for the withdrawal. Atty. Paras admitted he did not submit the SPA to RTC, Branch 18, but insisted he gave a copy to RTC, Branch 20.

Issue:

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Ruling:

• (Unlock)

Ratio:

1. Credibility of Testimonies:

   • The Court found Atty. Paras' account more credible. It was unlikely that he would lose his temper without provocation, especially given Lofranco's sarcastic and disrespectful remarks.
   • Lofranco admitted to responding arrogantly, which the Court deemed inappropriate for a court employee.

2. Duty of Court Employees:

   • Court employees are expected to exhibit courtesy, civility, and self-restraint at all times, even when faced with rude or insulting behavior.
   • Lofranco's sarcastic remarks and failure to maintain professionalism were contrary to the high standards of ethics required in public service.

3. Improper Conduct of Both Parties:

   • While Atty. Paras also acted improperly by losing his temper, this did not justify Lofranco's discourteous behavior. Her role as a public servant required her to handle the situation with grace and professionalism.

4. Precedent on Discourtesy:

   • The Court cited previous cases where court employees were disciplined for discourtesy, emphasizing that such behavior undermines the dignity and respect of the judiciary.

5. Sanction:

   • Lofranco was reprimanded for her discourtesy and warned that any future misconduct would be met with more severe penalties.

Conclusion:

• The Supreme Court upheld the importance of maintaining professionalism and courtesy in the judiciary. Lofranco's actions were deemed unacceptable, and she was disciplined accordingly to uphold the integrity of the judicial system.