Case Summary (G.R. No. L-5640)
Procedural History
On March 12, 2003, Deputy Court Administrator ElepaAo notified Judge Galicano C. Arriesgado regarding Ms. Arnaez's tardiness, specifically referencing violations of Civil Service Commission (CSC) Memorandum Circular No. 23, Series of 1998, which outlines tardiness standards for government employees. ElepaAo directed that Ms. Arnaez be given 72 hours to explain her actions. In her explanation dated April 10, 2003, Ms. Arnaez cited her responsibilities as a single parent caring for her seven children as a reason for her tardiness.
Documentation of Tardiness
On March 15, 2004, Hermogena F. Bayani, a Supreme Court Judicial Staff Officer, provided a certification detailing Ms. Arnaez's tardiness, which included ten instances in August 2002, twelve in October 2002, ten in February 2003, and eleven in March 2003. Court Administrator Velasco, in his report on June 30, 2004, evaluated the evidence against Arnaez and determined that she met the criteria for habitual tardiness as defined in the aforementioned CSC memorandum.
Legal Framework and Findings
Civil Service Memorandum Circular No. 23, Series of 1998, specifies that an employee can be considered habitually tardy if they incur tardiness ten times in a month for at least two months. Velasco's evaluation indicated that Ms. Arnaez's habitual tardiness was unequivocal and that her justification based on familial obligations did not suffice to excuse her actions. Prior case law affirms that moral and domestic obligations cannot mitigate this rule.
Conclusion and Disciplinary Action
The findings culminated in a recommendation for reprimand rather than more severe penalties, noting that Ms. Arnaez's tardiness compromised the efficiency and integrity expected from judicial employees, who must serve as models of punctuality and public se
...continue readingCase Syllabus (G.R. No. L-5640)
Background of the Case
- The case revolves around Ma. Socorro E. Arnaez, a Court Stenographer III at the Regional Trial Court (RTC), Branch 18, Cebu City, who was reported for habitual tardiness.
- Deputy Court Administrator Zenaida N. ElepaAo informed Judge Galicano C. Arriesgado about Arnaez's tardiness in a letter dated March 12, 2003.
- The letter referenced a violation of the Civil Service Commission (CSC) Memorandum Circular No. 23, Series of 1998, which outlines the definition and consequences of habitual tardiness.
- Judge Arriesgado was instructed to require Arnaez to explain her tardiness within 72 hours.
Explanation Submitted by Ma. Socorro E. Arnaez
- On April 10, 2003, Arnaez submitted an explanation to Judge Arriesgado, detailing her familial responsibilities.
- She expressed that she is the sole caregiver for her seven children, managing both their needs and the household before departing for work.
- She noted that her husband visits infrequently, which adds to her burdens in managing the household.
Evidence of Habitual Tardiness
- Hermogena F. Bayani, a Supreme Court Judicial Staff Officer, issued a