In a significant ruling, the Supreme Court affirmed the dismissal of Crisostomo T. Molina, a Sheriff IV and Officer-In-Charge of the Office of the Clerk of Court, for grave misconduct, dishonesty, abuse of authority, and violation of Civil Service Rules. The Court emphasized that those involved in the administration of justice must adhere to the highest standards of ethical conduct and integrity. This case underscores the judiciary’s commitment to maintaining public trust by removing personnel who fail to meet these expectations, ensuring accountability and upholding the integrity of the judicial system.

Drunkenness, Derogatory Remarks, and Dishonest Travels: When Does Misconduct Merit Dismissal?

This case originated from a verified complaint filed by Marilou A. Cabanatan, a Court Stenographer III, against Crisostomo T. Molina, who held the position of Sheriff IV and Officer-In-Charge (OIC) of the Office of the Clerk of Court. The charges included abuse of authority, grave misconduct, oppression, dishonesty, and violation of Civil Service Rules. These charges stemmed from several incidents, including Molina’s alleged intoxication during office hours, his use of offensive language towards Cabanatan and other employees, the withholding of Cabanatan’s salary checks, and irregularities in his official travel documents and claims.

Executive Judge Jose Rosales, to whom the case was referred for investigation, found Molina guilty of the charges. Specifically, the investigation revealed that Molina had engaged in a drinking session inside the courtroom during office hours, leading to his intoxication. The investigation also confirmed that Molina used derogatory and challenging language towards his subordinates. Furthermore, the judge determined that Molina had unjustifiably withheld Cabanatan’s salary checks and submitted falsified travel documents to claim reimbursements for trips he purportedly made to the Supreme Court, without providing adequate proof of his visits. These actions, taken together, constituted a serious breach of the ethical standards expected of a court employee.

The Supreme Court, in its resolution, concurred with the findings and recommendation of Executive Judge Rosales. The Court emphasized the high standard of conduct required of those involved in the administration of justice, stating that “the conduct or behavior of everyone connected with an office charged with the dispensation of justice, from the presiding judge to the lowliest clerk, should be circumscribed with the heavy burden of responsibility.” The Court underscored the importance of maintaining moral righteousness and uprightness within the Judiciary, particularly for Clerks of Court, who are charged with safeguarding the integrity of the court and its proceedings. The Court noted that:

Part of this stringent requirement is that agents of the law should refrain from the use of language that is abusive, offensive, scandalous, menacing or otherwise improper. Judicial employees are expected to accord every due respect, not only to their superiors, but also to others and their rights at all times. Their every act and word should be characterized by prudence, restraint, courtesy and dignity.

The Court found that Molina’s actions fell short of these standards, as he admitted to participating in a drinking spree with his officemates inside the courtroom during official time and used inappropriate language towards his co-employees. Further, Molina’s dishonesty in submitting falsified travel orders and his failure to sign the attendance logbook were considered violations of Civil Service Rules and demonstrated a lack of integrity. In particular, his actions related to travel reimbursements raised serious concerns.

Executive Judge Rosales found that Molina’s certificates of appearance were signed by Judge Yadao at her office in Quezon City, contradicting the stated purpose of his travel orders to the Supreme Court. The Supreme Court agreed with the observation of former Honorable Court Administrator Alfredo L. Benipayo who stated: “[I]t quite odd for [J]udge Yadao to issue the Travel Orders and Certificates of Appearance of the respondent…[I]f t]he purpose of his travel were to bring urgent matters to Judge Yadao’s attention, if this [were] so, why would there be a Travel Order issued in advance? Why did the respondent present only the Certificate of Appearance issued by Judge Yadao in her capacity as Acting Presiding Judge of RTC, Branch 99, Quezon City, when his Travel Orders directed him to go to the Supreme Court to submit pertinent papers?’” Therefore, the Supreme Court held that such acts constituted dishonesty, which is unacceptable in the Judiciary. This determination hinged on the application of Sections 1 and 2, Rule XVII of the Rules Implementing Book V of Executive Order 292, (“The Administrative Code of 1987”) which provides:

Section 1. It shall be the duty of each head of the department or agency to require all officers and employees under him to strictly observe the prescribed office hours.

Section 2. Each head of the department or agency shall require a daily record of attendance of all the officers and employees under him including those serving in the field or on the water, to be kept on the proper form and, whenever possible, re-gistered on the bundy clock.

The Court emphasized the importance of maintaining the best possible individuals in the judiciary and its commitment to removing those who undermine the effective administration of justice, thereby tarnishing the image of the court. This is consistent with established jurisprudence, as the Court has stated: “[t]he judiciary demands the best possible individuals in the service. This Court will not hesitate to rid its ranks of undesirables who undermine its efforts towards an effective and efficient administration of justice, thus tainting its image in the eyes of the public.” Consequently, the Supreme Court ordered the dismissal of Crisostomo T. Molina from service, with forfeiture of all retirement benefits (except accrued leave credits) and with prejudice to reemployment in any branch or instrumentality of the government. The court’s decision emphasized the need for strict adherence to ethical standards and integrity in the judiciary to maintain public trust and ensure the effective administration of justice.

FAQs

What was the main reason for Crisostomo T. Molina’s dismissal?	Molina was dismissed due to grave misconduct, dishonesty, abuse of authority, and violation of Civil Service Rules, encompassing actions such as intoxication during office hours, use of offensive language, withholding of salary checks, and falsification of travel documents.
What specific ethical standards did Molina violate?	Molina violated standards of conduct expected of judicial employees, including the requirements to refrain from abusive language, maintain courtesy and dignity, and act with justness and sincerity. He also failed to adhere to Civil Service Rules regarding attendance and honesty in official travel claims.
What was the significance of Molina’s position in the court?	As the Sheriff IV and Officer-In-Charge of the Office of the Clerk of Court, Molina held a position of significant responsibility in the Judiciary, requiring a high level of moral righteousness, uprightness, and integrity to safeguard the integrity of the court and its proceedings.
What evidence supported the charge of dishonesty against Molina?	The charge of dishonesty was supported by evidence showing that Molina submitted falsified travel orders and certificates of appearance to claim reimbursements for trips to the Supreme Court, without providing adequate proof of his visits or the purpose of his travel.
What impact did Molina’s actions have on the public’s perception of the Judiciary?	Molina’s actions undermined the public’s trust in the Judiciary by demonstrating a lack of integrity and ethical conduct, thereby tarnishing the image of the court and its commitment to the effective administration of justice.
What disciplinary actions were taken against Molina?	Molina was dismissed from service with forfeiture of all retirement benefits, except accrued leave credits, and with prejudice to reemployment in any branch or instrumentality of the government, including government-owned or controlled corporations.
How does this case reinforce the Judiciary’s commitment to ethical conduct?	This case reinforces the Judiciary’s commitment to ethical conduct by demonstrating its willingness to remove personnel who fail to meet the high standards of integrity and accountability required of those involved in the administration of justice.
What should employees do when faced with ethical violations by their superiors?	Employees who witness ethical violations by their superiors should report such violations to the appropriate authorities, such as the Office of the Court Administrator, to ensure that the Judiciary maintains its integrity and accountability.

The Supreme Court’s decision in this case underscores the importance of upholding the highest standards of ethical conduct and integrity within the Judiciary. By dismissing an official for misconduct, dishonesty, and abuse of authority, the Court sends a clear message that such behavior will not be tolerated and that those who fail to meet these standards will be held accountable. This ruling serves as a reminder to all judicial employees of their responsibility to maintain the public’s trust and ensure the effective and fair administration of justice.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MARILOU A. CABANATAN vs. CRISOSTOMO T. MOLINA, A.M. No. P-01-1520, November 21, 2001