The Supreme Court’s decision in Adajar v. Develos underscores the importance of maintaining the dignity of the courts by strictly enforcing ethical standards for all court personnel. The Court found two court employees administratively liable for engaging in private business transactions within court premises and during office hours. This ruling reinforces that courts must be used exclusively for judicial functions, and all employees must adhere to the highest standards of conduct. By upholding Administrative Circulars No. 1-99 and 09-99, the Supreme Court reiterated its commitment to preserving the integrity of the judiciary and ensuring that court employees do not engage in activities that could compromise public trust.

Jewelry Sales at the RTC: Can Court Employees Engage in Personal Business on Government Property?

The case stemmed from a complaint filed by Luz C. Adajar, a businesswoman and local legislator, against Teresita O. Develos, Celsa G. Ellorin, and Cyrus A. Ellorin, all employees of the Regional Trial Court (RTC) in Malaybalay City, Bukidnon. Adajar alleged that Develos failed to pay the balance for jewelry she had delivered on consignment, and that Cyrus Ellorin had forcibly removed her from the RTC premises when she attempted to collect the debt. The incident exposed the practice of selling goods within the courthouse, prompting the Supreme Court to address whether such activities violated administrative rules and ethical standards for court employees. This case provides an opportunity to reinforce the principle that courts are temples of justice and must be free from activities that undermine their dignity.

The core issue before the Supreme Court was whether the respondents’ actions constituted violations of administrative circulars prohibiting the use of court premises for non-judicial functions and the selling of goods. The complainant, Adajar, claimed that she had a consignment arrangement with Develos, while the respondents countered that Adajar was directly selling jewelry to court employees, with Develos merely facilitating the transactions. The Investigating Judge initially recommended dismissing the complaint, adopting the findings of the Office of the Ombudsman, Mindanao, which had also dismissed a related administrative case. However, the Office of the Court Administrator (OCA) recommended that the respondents be reprimanded for violating Administrative Circular Nos. 09-99 and 1-99. This led the Supreme Court to conduct its own review of the case, focusing on whether the respondents had breached the ethical standards expected of court employees.

The Supreme Court emphasized its exclusive authority over the administrative supervision of all courts and court personnel, citing Article VIII, Section 6 of the 1987 Constitution. The Court quoted Maceda vs. Vasquez, stating:

Article VIII, Section 6 of the 1987 constitution exclusively vests in the Supreme Court administrative supervision over all courts and court personnel, from the Presiding Justice of the Court of Appeals down to the lowest municipal trial court clerk.  By virtue of this power, it is only the Supreme Court that can oversee the judges’ and court personnel’s compliance with all laws, and take the proper administrative action against them if they commit any violation thereof. No other branch of government may intrude into this power, without running afoul of the doctrine of separation of powers.

Building on this principle, the Court asserted that the Office of the Ombudsman, Mindanao, should have referred the complaint to the Supreme Court instead of resolving it. The Supreme Court also noted deficiencies in the Investigating Judge’s approach, as he relied heavily on the pleadings and the Ombudsman’s findings without conducting a thorough independent investigation. Despite these procedural issues, the Court proceeded to resolve the case based on the available records, considering the respondents’ request for a swift resolution and the complainant’s waiver to submit additional arguments.

The Court found that the quarrel between Adajar and the respondents occurred within the RTC premises during office hours and involved the collection of debts arising from Adajar’s jewelry business. The fact that Develos and Celsa had engaged in transactions with Adajar on court property was a critical factor in the Court’s decision. The Court emphasized that their dealings with Adajar, regardless of whether they were directly related to their official duties, contravened Administrative Circular Nos. 1-99 and 09-99. These circulars aim to maintain the dignity of the courts and promote respect for their officials and employees.

Administrative Circular No. 1-99 explicitly states:

Never use their offices as a residence or for any other purpose than for court or judicial functions.
Never permit the following to be done within the premises of the court: gambling, drinking of alcoholic beverages or any other form of improper or unbecoming conduct.

Moreover, Administrative Circular No. 09-99 directly prohibits the selling of goods within courthouses and offices. The Court reasoned that if selling is prohibited, then buying is also implicitly prohibited as it supports the act of selling. These regulations reinforce the idea that court premises should be reserved exclusively for court-related activities, thereby upholding the integrity and dignity of the judiciary.

The Court concluded that Develos and Celsa’s act of buying jewelry from Adajar in their office, and Develos’s facilitation of Adajar’s sales, constituted a violation of these administrative circulars. The Supreme Court has consistently held that court personnel must act with strict propriety and decorum to maintain public regard for the judiciary. While the Court acknowledged that Adajar failed to substantiate her claim that Develos still owed her P20,000.00, the administrative violations committed by Develos and Celsa were sufficient grounds for disciplinary action.

Regarding Cyrus Ellorin, the Court found insufficient evidence to support Adajar’s allegations that he engaged in a shouting match or forcibly removed her from the office. Similarly, there was no substantial evidence to prove that Celsa hurled insults at Adajar. The Court reiterated the principle that in administrative proceedings, the complainant bears the burden of proving the allegations with substantial evidence. Since Adajar failed to meet this burden with respect to Cyrus and Celsa, the complaints against them were dismissed.

The Supreme Court classified the violation of office rules and regulations as a light offense under Section 52(C)(3), Rule IV of the Uniform Rules on Administrative Cases in the Civil Service. As this was Develos and Celsa’s first offense of this nature, the Court deemed a reprimand to be the appropriate penalty. This decision aligns with the principle that disciplinary measures should be proportionate to the offense committed, balancing the need to maintain ethical standards with fairness to the individuals involved.

FAQs

What was the key issue in this case?	The key issue was whether court employees violated administrative rules by engaging in private business transactions within court premises and during office hours, thereby undermining the dignity of the courts.
What administrative circulars were violated in this case?	Administrative Circular Nos. 1-99 and 09-99 were violated. Circular 1-99 prohibits using court offices for non-judicial functions, while Circular 09-99 bans selling goods within courthouses.
What was the Supreme Court’s ruling?	The Supreme Court found two court employees, Teresita O. Develos and Celsa G. Ellorin, guilty of violating the administrative circulars and reprimanded them. The complaint against the third employee, Cyrus A. Ellorin, was dismissed for lack of evidence.
Why did the Court emphasize administrative supervision?	The Court emphasized its exclusive authority over the administrative supervision of all courts and court personnel, ensuring that ethical standards are upheld within the judiciary.
What standard of evidence is required in administrative cases?	In administrative proceedings, the complainant must provide substantial evidence to support their allegations, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
What is the significance of classifying the violation as a “light offense”?	Classifying the violation as a light offense under the Civil Service rules led to the imposition of a reprimand, which is the appropriate penalty for a first-time violation of reasonable office rules and regulations.
How does this case relate to the concept of courts as “temples of justice”?	This case reinforces the principle that courts must be free from activities that undermine their dignity and integrity, ensuring that they serve as temples of justice where judicial functions are prioritized.
What should court employees avoid to prevent similar violations?	Court employees should avoid engaging in any form of private business or non-judicial activities within court premises or during office hours to maintain the ethical standards required of public servants.

The Supreme Court’s decision in Adajar v. Develos serves as a crucial reminder that all court personnel are expected to uphold the highest ethical standards and avoid any conduct that could compromise the integrity of the judiciary. By enforcing Administrative Circulars No. 1-99 and 09-99, the Court has reaffirmed its commitment to maintaining the dignity of the courts and ensuring public trust in the justice 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: LUZ C. ADAJAR, VS. TERESITA O. DEVELOS, G.R. No. 42175, November 18, 2005