Title
Villanueva vs. Saguyod
Case
A.M. No. P-13-3102
Decision Date
Sep 8, 2014
Clerk of Court Saguyod suspended for 3 months for demanding unauthorized fees, hostile behavior, and violating ethical standards in handling public requests.

Case Summary (A.M. No. P-13-3102)

Allegations Against the Respondent

Jose S. Villanueva filed a complaint against Atty. Paulino I. Saguyod for violating the Code of Conduct for Court Personnel and Section 4(e) of Republic Act No. 6713. The complaint arose from an incident on February 20, 2007, when Villanueva requested a certified photocopy of a petition related to Land Case No. 051-06. Respondent denied the request, demanding a Special Power of Attorney and subsequently engaging in unprofessional and aggressive behavior towards Villanueva, including threats of physical violence.

Respondent's Defense

In his comment, respondent Saguyod denied the allegations, maintaining that he required written authority for the document request as per court policy. He asserted that Villanueva's text message did not constitute sufficient authorization, and he described the interaction as an escalation initiated by Villanueva's rude behavior. Saguyod's defense included claims that his wife's occasional presence in the office was unmalicious and unrelated to his professional duties.

Investigation and Findings

The case was referred to Executive Judge Liberty O. Castañeda for investigation. Although initially recommending dismissal for lack of merit, her report was later nullified due to her being under preventive suspension. The case was subsequently reassigned to another judge for further examination. The Office of the Court Administrator (OCA) later found that Saguyod exhibited misconduct for demanding an improper payment of P3,000 as a commissioner's fee, which contravened established court policies.

Court's Rationale on Misconduct

The court underscored the critical administrative role of clerks of court in ensuring the integrity of judicial processes. It was established that Saguyod's demand for P3,000 was unauthorized and inconsistent with the applicable rules, which only provide for reasonable fees in specific contexts. Such behavior warranted a determination of simple misconduct, as clerks are prohibited from personally benefiting from fees linked to their official duties.

Issues Concerning Service and Conduct

The court recognized that while Saguyod's refusal to provide the document was in line with procedural integrity, his confrontational demeanor and refusal to extend courtesy violated the ethical standards outlined in Republic Act No. 6713. Testimonies confirmed that both parties exhibited unprofessional behavior; however, as a public officer, Saguyod was held to a higher standard of conduct, which he failed to uphold.

Final Holdings and Penaltie

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