In Lim v. Aromin, the Supreme Court addressed the ethical responsibilities of court personnel, ruling that a court employee who interferes with the execution of a judgment to benefit a friend violates the Code of Conduct for Court Personnel. This decision underscores the judiciary’s commitment to impartiality and public trust, emphasizing that court employees must uphold the law and avoid even the appearance of impropriety.

When Friendship Clouds Judgment: Can Court Personnel Interfere with Legal Processes?

This case arose from a complaint filed by Angelina C. Lim and Vivian M. Gaduang against Maribeth G. Aromin, a Records Officer at the Municipal Trial Court of Meycauayan, Bulacan. The complainants alleged that Aromin violated the Code of Ethical Standards for Public Officials and Employees by interfering with the execution of a judgment in their favor. The central issue was whether Aromin, by attempting to halt the execution of a sheriff’s sale at the request of a friend, abused her position and compromised the integrity of the judiciary.

The facts revealed that on November 8, 2006, Lim and Gaduang went to a warehouse to claim properties awarded to them through a court decision. Aromin arrived and ordered them to stop, claiming someone would bring a court order to halt the sale. Complainants stated that Aromin shouted invectives at them. Aromin countered that she was summoned by the warehouse owner, Billy Lim, a close friend, to seek police assistance and stop the removal of items due to the absence of a sheriff. She denied shouting invectives and claimed the complaint was harassment because she was a witness in a robbery and trespassing case Billy Lim filed against the complainants.

The Office of the Court Administrator (OCA) directed Aromin to comment on the complaint, and subsequently referred the case to the Executive Judge of the Regional Trial Court of Malolos, Bulacan, for investigation. The Investigating Judge found Aromin guilty of improper conduct but noted that the allegation of shouting invectives was unsubstantiated due to the complainants’ failure to attend the hearings. Nevertheless, the judge concluded that Aromin’s actions of using her position to help a friend stop a court-ordered execution was inappropriate.

The OCA adopted the Investigating Judge’s findings, holding Aromin guilty of violating Section 1, Canon IV of the Code of Conduct for Court Personnel and Conduct Unbecoming of a Court Personnel. The Supreme Court agreed with the OCA’s assessment, emphasizing the importance of court personnel devoting their official time to public service and maintaining a high degree of professionalism. According to Section 1, Canon IV of the Code of Conduct for Court Personnel:

Court personnel shall commit themselves exclusively to the business and responsibilities of their office during working hours.

The Court emphasized that Aromin herself admitted being at the warehouse on November 8, 2006, to stop the execution of the certificate of sheriff’s sale at the request of Billy Lim. The Court also highlighted that Aromin failed to devote her time exclusively to her official duties, involving herself in personal matters during office hours. The Supreme Court held that this interference was a clear violation of the ethical standards expected of court employees. The Supreme Court emphasized that the actions of court personnel reflect on the entire judiciary, stating:

Employees of the judiciary should be living examples of uprightness not only in the performance of official duties but also in their personal and private dealings with other people so as to preserve at all times the good name and standing of the courts in the community. The image of the court, as being a true temple of justice, is aptly mirrored in the conduct, official or otherwise, of the men and women who work thereat, from the judge to the least and lowliest of its personnel.

To further understand the basis of the ruling, here’s a comparison of the perspectives:

Complainants’ Perspective	Respondent’s Perspective
Aromin interfered with a legal process by ordering them to stop loading properties awarded by the court.	She was merely responding to a call for assistance from a friend and did not act maliciously or with improper motive.
Aromin’s presence at the warehouse and her attempts to stop the execution were inappropriate for a court employee.	She was acting as a concerned citizen and assisting in preventing what she believed was an unlawful act due to the absence of a sheriff.
Aromin shouted invectives at them, demonstrating unprofessional conduct.	She denied shouting invectives and claimed the allegations were fabricated as part of a harassment campaign.

The Court found Aromin’s interference with the execution of the certificate of sheriff’s sale to be particularly disturbing, highlighting that she acted on behalf of a friend without considering the impropriety of her actions as a court employee. This, the Court noted, led complainants to believe that Aromin was using her position to favor Billy Lim, undermining the NLRC decisions and orders in favor of the complainants. This decision reinforces the principle that public servants must prioritize public interest over personal interest at all times.

FAQs

What was the key issue in this case?	The key issue was whether a court employee violated the Code of Conduct for Court Personnel by interfering with the execution of a judgment to benefit a friend.
Who were the parties involved in the case?	The parties involved were Angelina C. Lim and Vivian M. Gaduang (complainants) and Maribeth G. Aromin, a Records Officer at the Municipal Trial Court of Meycauayan, Bulacan (respondent).
What did Maribeth G. Aromin do that led to the complaint?	Maribeth G. Aromin interfered with the execution of a certificate of sheriff’s sale at the request of a friend, attempting to stop the process.
What Code of Conduct did Aromin violate?	Aromin was found guilty of violating Section 1, Canon IV of the Code of Conduct for Court Personnel, which requires court personnel to commit themselves exclusively to their office duties during working hours.
What was the Court’s ruling in this case?	The Court found Aromin guilty of violating the Code of Conduct and fined her P5,000.00, with a stern warning against repeating similar acts.
Why did the Court view Aromin’s actions as a violation?	The Court viewed Aromin’s actions as a violation because she used her position as a court employee to interfere with a legal process for personal reasons, thereby compromising the integrity of the judiciary.
What is the significance of this ruling?	The ruling emphasizes the importance of ethical conduct among court personnel and reinforces the principle that public servants must prioritize public interest over personal interest.
What does the Code of Conduct for Court Personnel emphasize?	The Code emphasizes the importance of professionalism, integrity, and impartiality among court personnel, ensuring they uphold the public’s trust in the judicial system.

The Supreme Court’s decision serves as a crucial reminder to all court employees about the ethical standards they must uphold. It reinforces that the judiciary demands the highest level of integrity and impartiality from its personnel, ensuring public trust in the administration of justice. This case illustrates that even seemingly minor actions can have significant consequences if they undermine the principles of fairness and objectivity.

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: ANGELINA C. LIM AND VIVIAN M. GADUANG, COMPLAINANTS, VS. MARIBETH G. AROMIN, RECORDS OFFICER I, OFFICE OF THE CLERK OF COURT, MUNICIPAL TRIAL COURT, MEYCAUAYAN, BULACAN, RESPONDENT., 51445