The Supreme Court held that a court stenographer’s unauthorized travel abroad, misrepresentation in her leave application, and failure to transcribe stenographic notes constitute dishonesty and gross neglect of duty. This ruling underscores the high standards of conduct expected of public servants, particularly those in the judiciary, and emphasizes the importance of honesty, integrity, and compliance with administrative regulations. The decision serves as a warning that such misconduct will be met with severe disciplinary action, including dismissal from service.

Leaving the Country, Leaving Duty Behind: When Personal Ambition Conflicts with Public Trust

This case revolves around Raquel S. Bautista, a Stenographer I at the Municipal Trial Court of Guiguinto, Bulacan, and the administrative charges filed against her by Judge Luis Enriquez Reyes. The charges stemmed from Bautista’s actions of traveling abroad without the Supreme Court’s permission, misrepresenting her leave application, and failing to complete her stenographic transcriptions in a timely manner. The heart of the matter lies in whether Bautista’s conduct constitutes a breach of duty serious enough to warrant disciplinary action, considering the stringent standards of behavior expected from those serving in the judiciary.

The sequence of events began with Bautista’s application for a 22-day leave, followed shortly by another application extending her leave for several months. According to Judge Reyes, he approved these leaves without suspecting Bautista’s true intentions, which were to work overseas. Upon discovering that Bautista had left the country and had several pending transcriptions, Judge Reyes initiated the complaint, citing her misrepresentation and dereliction of duty. As the Court noted in OCA Circular No. 6-2003:

VI. Leave to be Spent Abroad.

All foreign travels of judges and court personnel, regardless of the number of days, must be with prior permission from the Supreme Court through the Chief Justice and the Chairmen of the Divisions pursuant to the resolution in A.M. 99-12-08-SC (Memorandum Order No. 14-2000 dated 6 November 2000).

In her defense, Bautista admitted to traveling abroad for employment opportunities but claimed urgency and cited her family’s need for a better future. She also contended that some of the listed transcriptions were not her responsibility and that her husband had attempted to submit the completed notes, which Judge Reyes refused to accept. However, the Office of the Court Administrator (OCA) found her explanations insufficient and recommended her dismissal, a recommendation that the Supreme Court ultimately upheld.

The Supreme Court emphasized that Bautista’s actions were in direct violation of existing circulars and constituted serious misconduct. The Court highlighted OCA Circular No. 49-2003, which explicitly requires court personnel to secure a travel authority from the Office of the Court Administrator before traveling abroad, regardless of the duration. Moreover, the misrepresentation in Bautista’s leave application was deemed an act of dishonesty, further compounding her offenses. In the case of Recio v. Acuña, the Supreme Court previously addressed a similar situation, stating:

Acuña is likewise guilty of dishonesty for applying for a sick leave on the pretext that he was seriously ill, in order to conceal his absence from the country. This is just one of the several grounds for disciplinary action that he committed under P.D. 807, Section 36(b) Article IX.

The Court also pointed to Bautista’s failure to transcribe stenographic notes within the prescribed 20-day period as a sign of gross neglect of duty. Administrative Circular No. 24-90 explicitly requires stenographers to transcribe their notes within this timeframe, highlighting the importance of timely record-keeping in judicial proceedings. In conjunction with the violation of Supreme Court administrative circulars, the act of leaving the country without completing pending transcriptions also constitutes a serious breach of duty. The Court cited Ibay v. Lim, where a court stenographer was found guilty of similar offenses, reinforcing the principle that such behavior is unacceptable within the judiciary.

The Supreme Court’s decision underscores the importance of maintaining the integrity and efficiency of the judicial system. The Court stressed that the image of justice is reflected in the conduct of all court personnel, from judges to the lowest-ranking employees. The Court noted:

the image of a court of justice is necessarily mirrored in the conduct, official or otherwise, of the men and women who work thereat, from the judge to the least and lowest of its personnel – hence, it becomes the imperative sacred duty of each and everyone in the court to maintain its good name and standing as a true temple of justice.

This expectation necessitates adherence to administrative rules and regulations, as well as a commitment to honesty and diligence in performing one’s duties. Consequently, any deviation from these standards can result in severe consequences. Therefore, the Court found Bautista guilty of dishonesty, gross neglect of duty, and violation of Supreme Court administrative circulars, ordering her dismissal from service with forfeiture of benefits and privileges.

FAQs

What was the key issue in this case?	The key issue was whether Raquel S. Bautista, a court stenographer, should be disciplined for traveling abroad without permission, misrepresenting her leave application, and failing to complete her transcriptions. The Supreme Court examined if her actions constituted dishonesty and gross neglect of duty.
Why was the stenographer charged with misconduct?	She was charged with misconduct because she traveled abroad without securing the necessary permission from the Supreme Court, misrepresented that her leave would be spent within the Philippines, and failed to submit her stenographic notes within the required period. These actions violated administrative rules and regulations.
What did the stenographer claim in her defense?	She argued that she needed to work overseas to provide a better future for her family. She admitted to having pending transcripts but claimed some were not her responsibility and that her husband attempted to submit them.
What did the Office of the Court Administrator (OCA) recommend?	The OCA recommended that Bautista be dismissed from service with forfeiture of benefits and with prejudice to reemployment in the government. This was based on their assessment of the severity of her misconduct.
What relevant circulars did the stenographer violate?	She violated OCA Circular No. 6-2003 and OCA Circular No. 49-2003, which require court personnel to obtain permission for foreign travel. She also violated Administrative Circular No. 24-90, which mandates timely transcription of stenographic notes.
What was the significance of the Recio v. Acuña case?	Recio v. Acuña was cited to support the finding of dishonesty. In that case, a sheriff was dismissed for going on sick leave to cover up overseas employment, similar to Bautista’s misrepresentation.
What was the significance of the Ibay v. Lim case?	Ibay v. Lim was cited to reinforce the finding of gross neglect of duty and violation of administrative circulars. In that case, a court stenographer was also found guilty for traveling abroad with pending untranscribed notes.
What was the final ruling of the Supreme Court?	The Supreme Court found Bautista guilty of dishonesty, gross neglect of duty, and violation of Supreme Court administrative circulars. She was dismissed from service with forfeiture of all benefits and privileges, with prejudice to re-employment in any government branch.

This case serves as a stark reminder of the responsibilities and ethical standards expected of public servants in the Philippines, particularly within the judiciary. By upholding the dismissal of Raquel S. Bautista, the Supreme Court reaffirmed its commitment to maintaining the integrity and efficiency of the judicial system and promoting public trust in government institutions.

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: JUDGE LUIS ENRIQUEZ REYES vs. RAQUEL S. BAUTISTA, A.M. NO. P-04-1873, January 13, 2005