Title
Escleo vs. Dorado
Case
A.M. No. P-99-1312
Decision Date
Jul 31, 2002
Court stenographer solicited unauthorized fees, facilitated marriage license circumvention; suspended for misconduct, violating ethical standards.
A

Case Summary (A.M. No. P-99-1312)

Allegations Against Respondent

The complaint details that on January 8, 1998, Ma. Phoebe Q. Carbon, sister of the complainant, sought a marriage license at the City Hall of Makati. Dorado allegedly solicited P2,000.00 as a down payment towards an inflated fee of P4,000.00, which was negotiated down from an initial asking price of P5,000.00. Escleo's complaint asserts that Dorado misappropriated both the down payment and the document necessary for the marriage, leading to a conflict initiated by Escleo demanding the return of funds and documents.

Investigation by the Court

After receiving the complaint, MeTC Judge Estella Bernabe was made aware of the situation between the parties. She advised Escleo that no fees should have been charged for solemnizing a marriage and instructed her to submit a written complaint. Following her guidance, Escleo formally lodged her complaint with Executive Judge Leticia Ulibarri, leading to an investigation conducted on January 13 and 14, 1998, which was attended by both parties and later referred to the Office of the Court Administrator (OCA).

Respondent's Defense

In reaction to the formal charges, Dorado submitted an affidavit denying solicitation of any money and claimed she was merely attempting to assist the engaged couple with the marriage license process. She argued that she had referred Carbon to another party for further assistance and shrugged off any claims of wrongdoing by stating the complainant overreacted and was verbally aggressive.

Findings of Misconduct and Procedural Challenges

As the investigation unfolded, testimony from several witnesses, including those present during the complainant’s explosive confrontation with Dorado, depicted a tumultuous relationship. Justice Quimbo, assigned to investigate further, found that while Dorado’s actions did not constitute gross misconduct, they still represented a significant breach of professional conduct. The discussion revolved around due process rights, with Dorado arguing her rights were violated due to the complainant's absence during administrative hearings.

Ruling and Penalty

Ultimately, the Supreme Court found Dorado guilty of Simple Misconduct, confirming the recommendation for a three-month suspension was excessive given it was her first off

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