G.R. No. 99287 - People vs. Villarama, Jr.

Jose S. Villanueva filed a complaint on March 23, 2007 against Atty. Paulino I. Saguyod, Clerk of Court VI of RTC, Paniqui, Tarlac.
The complaint charged Saguyod with violations of the Code of Conduct for Court Personnel and Section 4(e) of Republic Act No. 6713 (the Code of Ethics for Public Officials and Employees).

On February 20, 2007, complainant received a text message from Atty. Lavezares Leomo instructing him to secure a certified photocopy of a petition related to Land Case No. 051-06.
Complainant visited RTC, where he was initially attended by stenographer Ms. Rosalie D. Sarsagat, who informed him to return after thirty minutes due to the unavailability of the records’ custodian.

After the waiting period, complainant was informed that the records were in the custody of respondent, but that he had to speak with Saguyod’s wife, Mrs. Judith Saguyod, who was also present in the records area despite not being an official employee of the court.
When complainant requested the photocopy with a text message as proof of his authority, respondent questioned whether he possessed a Special Power of Attorney authorizing him to secure the document.

During the exchange, respondent’s wife involved a third party by contacting the Register of Deeds of Tarlac, and subsequently stated that the petition would not be released.
The dialogue escalated when respondent made derogatory remarks and challenged complainant to a physical fight, using phrases such as “Punyeta ka!” and “Tarantado ka.”
Complainant explained that his request was based on instructions from his employer and that he had no improper intentions, while respondent continued to issue provocative statements.
To defuse the situation, complainant attempted to leave, but respondent blocked his exit and continued to exchange heated words, even involving comments about the respondent’s geographic affiliation (Paniqui versus Victoria).
The altercation extended to physical gestures, including respondent patting and pushing complainant, and further verbal abuse which included gender-based insults directed at his wife.

Complainant alleged that the offensive behavior was partly motivated by respondent’s displeasure over complainant’s failure to pay the full balance of P1,500 for a Certificate of Finality related to Land Cases Nos. 021-P06 and 020-P06.
When complainant followed up on the issuance of the Certificate of Finality, he was told by Ms. Sarsagat that respondent would not sign the certificate unless an additional fee of P3,000 was paid.
Complainant made the advance payment of P1,500, which he later disputed as being mishandled, while respondent accused complainant of repeatedly defaulting on such payments.

The administrative complaint was initially referred to the Executive Judge of RTC, Paniqui, Tarlac, then subsequently to Acting Presiding Judge Alipio C. Yumul for further investigation and recommendation.
Judge Yumul recommended the dismissal of the case; however, the Office of the Court Administrator (OCA) later evaluated the matter and recommended re-docketing as a regular administrative case with specific sanctions.

The case involved multiple issues: the alleged improper demand for fees, the propriety of the fee received for reception of evidence, the quality of service provided by the respondent, and the allegation concerning the official capacity of the respondent’s wife in the court office.

Whether or not respondent indirectly demanded and received an amount of P3,000 as commissioneras fee and appearance fee for the processing of the Certificate of Finality related to Land Case Nos. 021-P06 and 020-P06.
Whether the collection of commissioneras fee for the reception of evidence by a court employee is legal and proper under the applicable rules and regulations.
Whether respondent extended prompt, courteous, and proper service to complainant when requested to secure a certified photocopy of a petition.
Whether respondent’s wife held office in the Office of the Clerk of Court, thereby potentially creating a conflict of interest in the handling of official records and transactions.