The Supreme Court held that any act of impropriety by court personnel, especially those expected to preserve the judiciary’s image, will not be tolerated. Atty. Gilbert Soriano, a Court Attorney, was dismissed for extorting money from a party-litigant by falsely claiming to be a Supreme Court Justice. This decision underscores the high standard of conduct required of those in the administration of justice and reinforces the principle that public office is a public trust, demanding utmost integrity and accountability.

Justice Impersonated: When Court Employees Exploit Public Trust

The case of Doroteo Igoy v. Atty. Gilbert Soriano arose from a grave breach of ethical conduct by a court employee. Doroteo Igoy, a party in a case before the Supreme Court, filed a complaint against Atty. Gilbert Soriano, a Court Attorney, alleging that Soriano misrepresented himself as a Justice of the Supreme Court and solicited money in exchange for assistance with his case. Igoy claimed that Soriano received P20,000 initially and later demanded an additional P20,000 to prepare a petition for review. The funds were sent via courier and received by Soriano’s son, Alvin Soriano. Despite the payment, the Supreme Court denied Igoy’s petition, leading him to discover Soriano’s true position within the court.

In his defense, Atty. Soriano denied the allegations, claiming that Igoy offered the money as a “token of gratitude” for reviewing his petition. He admitted receiving the money but denied any misrepresentation or solicitation. Soriano further stated that he intended to return the money upon learning its purpose but was instructed to wait for instructions from Igoy’s counsel. Despite Soriano’s denials, the Supreme Court found substantial evidence to support Igoy’s claims. The evidence included the courier receipt addressed to Soriano, a letter authorizing his son to receive the package, and the admission that the money was indeed received.

The Supreme Court emphasized the duty of lawyers, particularly those in public service, to uphold the dignity and authority of the court. The court cited Villaflor v. Sarita, stating that it is a lawyer’s foremost responsibility “to observe and maintain the respect due to the courts of justice and judicial officers.” The Court found that Soriano’s actions constituted a severe betrayal of this duty, warranting severe disciplinary action. The Court also referenced NBI v. Judge Ramon B. Reyes, emphasizing that misconduct by those administering the law erodes respect for the legal system. The Court rejected Soriano’s resignation as an attempt to evade accountability, reinforcing that disciplinary proceedings serve public welfare, not private interests, and aim to protect the integrity of the courts.

Central to the Court’s decision was the violation of Republic Act No. 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees. Section 7(d) of R.A. 6713 explicitly prohibits public officials and employees from soliciting or accepting gifts or anything of monetary value in the course of their official duties or in connection with any transaction affected by their office.

Sec. 7. Prohibited Acts and Transactions

d. Solicitations or acceptance of gifts – Public officials and employees shall not solicit or accept, directly or indirectly, any gift, gratuity, favor, entertainment, loan or anything of monetary value from any person in the course of their official duties or in connection with any operation being regulated by, or any transactions which may be affected by the functions of their office.

The Court found that Soriano, as a lawyer and court employee, should have avoided any situation that could create the impression of using his office for personal gain. The Court noted that his actions tainted the integrity of the judiciary. The Court dismissed Soriano’s claim that the money was a gratuitous gift, stating that tolerating such acts would open the door to fraud and corruption within the court system. The Supreme Court held that attempts to return the money after the complaint was filed did not absolve Soriano of his administrative liabilities. The Court emphasized that the act itself constituted a disservice to the administration of justice, damaging the image of the court.

The Supreme Court explicitly adopted the findings and recommendations of the Office of Administrative Services (OAS), which highlighted that Soriano exploited his position to give the complainant the impression that he had influence within the court. The OAS noted that Soriano’s decision to assist Igoy, despite it not being his official duty, suggested to Igoy that a fee was expected. Building on this principle, the court emphasized that all officials and employees involved in the administration of justice must maintain strict propriety and decorum to earn and maintain public respect for the judiciary. This duty is further emphasized by Canon 6, Rule 6.02 of the Code of Professional Responsibility, which prohibits government lawyers from using their public position to advance private interests or allowing such interests to interfere with public duties.

The Court also cited several precedents to underscore the gravity of Soriano’s misconduct. In In Re: Derogatory News Items Charging Court of Appeals Associate Justice Demetrio Demetria with Interference on Behalf of a Suspected Drug Queen, the Court stressed that those in the courts must conduct themselves with honor, probity, fairness, prudence, and discretion, avoiding any appearance of impropriety. Further, in RTC Makati Movement Against Graft and Corruption v. Dumlao, the Court reiterated that the responsibilities of public officers are not mere rhetorical words but working standards. Also, Solidbank Corporation v. Capoon highlights the strictest standards of honesty and integrity required in public service. The Supreme Court emphasized that the administration of justice is a sacred task, requiring the highest standards of honesty, integrity, and uprightness from all involved.

The Court also reiterated that any act falling short of the exacting standards for public office, especially those expected to preserve the judiciary’s image, will not be tolerated. The Court referenced Office of the Court Administrator v. Cabe and Mendoza v. Mabutas to underscore that even the appearance of impropriety or negligence can diminish public faith in the judiciary. Therefore, Soriano’s actions, as a senior attorney of the Supreme Court, seriously undermined public trust in the judicial system. By misrepresenting himself and soliciting money, he irrevocably damaged his career and prejudiced the integrity of the Court.

FAQs

What was the central issue in this case?	The central issue was whether Atty. Gilbert Soriano, a court employee, should be held administratively liable for misrepresenting himself as a Supreme Court Justice and soliciting money from a litigant.
What did the complainant allege against Atty. Soriano?	The complainant, Doroteo Igoy, alleged that Atty. Soriano misrepresented himself as a Justice of the Supreme Court and solicited P40,000 in exchange for assistance with his case.
What was Atty. Soriano’s defense?	Atty. Soriano denied the allegations, claiming that the money was a gratuitous gift for reviewing the complainant’s petition and that he never misrepresented himself.
What evidence did the complainant provide?	The complainant provided a courier receipt addressed to Atty. Soriano, a letter authorizing his son to receive the package containing the money, and the petition for review allegedly prepared by Soriano.
What is R.A. 6713 and why is it relevant to this case?	R.A. 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees, prohibits public officials from soliciting or accepting gifts in connection with their official duties, which Atty. Soriano was found to have violated.
What was the Supreme Court’s ruling?	The Supreme Court ruled that Atty. Soriano was guilty of misconduct and dismissed him from service with forfeiture of all retirement benefits and with prejudice to reemployment in any government branch.
Why did the Court reject Atty. Soriano’s resignation?	The Court rejected Atty. Soriano’s resignation because resignation should not be used as an escape from administrative liability, and disciplinary proceedings serve the public interest, not private interests.
What is the significance of this case for court employees?	This case emphasizes the high standard of conduct required of court employees and reinforces the principle that public office is a public trust, demanding utmost integrity and accountability.

The Supreme Court’s decision serves as a stern warning to all public servants, particularly those in the judiciary, that any form of misconduct that undermines public trust will be met with severe consequences. The dismissal of Atty. Gilbert Soriano underscores the Court’s unwavering commitment to maintaining the integrity of the judicial system.

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: DOROTEO IGOY VS. ATTY. GILBERT SORIANO, A.M. No. 2001-9-SC, October 11, 2001