The Supreme Court held a court stenographer liable for Simple Neglect of Duty for failing to prepare an order of referral, emphasizing the importance of diligence among court personnel. Despite eventually issuing the order, the initial failure prejudiced the parties involved and warranted disciplinary action. This ruling underscores that public officers must be accountable and efficient, as even seemingly minor tasks contribute significantly to the justice system’s integrity and public trust.

The Case of the Missing Order: When Negligence Hinders Justice

In 2011, Ione Bethelda C. Ramos filed a complaint against Reba A. Beligolo, a court stenographer, for Grave Misconduct and Conduct Unbecoming a Court Employee. The case stemmed from Beligolo’s failure to prepare an order of referral for a mediation proceeding, which Ramos needed as the attorney-in-fact for one of the parties. Despite a court order instructing the parties to attend mediation and obtain the referral order, Beligolo’s negligence caused a delay. This situation raised questions about the responsibilities of court personnel and the consequences of failing to perform assigned duties. The Supreme Court’s decision addresses these concerns by reinforcing the importance of diligence and accountability within the judiciary.

The case began when Judge Agreda directed parties in a civil case to attend mediation and secure an order of referral. Ramos diligently followed up, but Beligolo failed to produce the order. According to Ramos, Beligolo sarcastically stated she was unable to prepare the order, leading to a contentious exchange. Beligolo countered that there was an internal agreement that the clerk of court could issue the order or delegate the task to other employees. She claimed she assumed another employee had completed the task to avoid delay. Despite the subsequent issuance of the order, the initial failure caused the parties to miss the scheduled mediation.

The Office of the Court Administrator (OCA) found Beligolo liable for Simple Neglect of Duty. The OCA emphasized that Beligolo did not deny the task was hers. Her assumption that another employee had handled it was imprudent. This inattention resulted in the rescheduling of mediation, prejudicing the parties. However, the OCA clarified that Beligolo’s actions did not constitute Grave Misconduct. Her transgression lacked unlawful intent, gross negligence, corruption, or willful disregard for established rules. Also, there was not enough evidence to prove that Beligolo exhibited irate, sarcastic, or disrespectful behavior to warrant Conduct Unbecoming of a Court Employee.

The Supreme Court adopted the OCA’s findings, highlighting Section 1, Canon IV of the Code of Conduct for Court Personnel. This canon mandates that court personnel must perform official duties properly and diligently. The Court has consistently held that all individuals involved in administering justice bear a heavy responsibility. They must perform their duties with utmost efficiency and competence. The failure to prepare the order of referral was a clear breach of this duty.

“Court personnel shall at all times perform official duties properly and with diligence.”

The Court defined Simple Neglect of Duty as the failure to give proper attention to a required task due to carelessness or indifference. The Court noted that this conclusion remained valid even though the parties eventually obtained the order and attended mediation. The initial failure to fulfill her responsibility constituted neglect. Beligolo had been previously found guilty of Simple Neglect of Duty for failing to submit stenographic notes on time. Given this prior offense, the standard penalty would have been dismissal from service.

Despite the seemingly warranted penalty of dismissal, the Supreme Court has the discretion to temper justice with mercy. In a similar case, Re: Illegal and Unauthorized Digging and Excavation Activities inside the Supreme Court Compound, Baguio City, a court employee also faced a second charge of Simple Neglect of Duty. Instead of dismissal, the Court imposed a two-year suspension without pay, considering the employee’s long service in the Judiciary. The Court decided to take a similar approach in Beligolo’s case. The Court acknowledged her nearly fifteen years of service in the judiciary. As such, it deemed a suspension more appropriate than dismissal.

Consequently, the Court ordered Beligolo’s suspension for two years without pay, cautioning against future similar offenses. The Court also made a final reminder that public officers must be accountable. They must serve with the utmost degree of responsibility and efficiency. Any act that falls short of these standards is unacceptable, especially for those responsible for upholding the judiciary’s image. Every member of the court has a duty to maintain its good name as a true temple of justice.

FAQs

What was the key issue in this case?	The key issue was whether Reba A. Beligolo, a court stenographer, should be held administratively liable for failing to prepare an order of referral, which constitutes Simple Neglect of Duty. The court examined whether her actions warranted disciplinary measures, considering her responsibilities and the impact of her negligence.
What is Simple Neglect of Duty?	Simple Neglect of Duty is defined as the failure of an employee to give proper attention to a required task or to discharge a duty due to carelessness or indifference. It involves a lack of diligence or attention to one’s responsibilities.
What penalty did the court impose on Beligolo?	The court suspended Beligolo for a period of two years without pay, considering her nearly fifteen years of service in the judiciary and the fact that she had previously been found liable for Simple Neglect of Duty. This was a tempered penalty in lieu of dismissal.
Why was Beligolo not dismissed from service, given her prior offense?	Although the standard penalty for a second offense of Simple Neglect of Duty is dismissal, the Supreme Court has the discretion to temper the harshness of its judgment with mercy. The Court considered Beligolo’s long years of service in the judiciary.
What is the significance of Canon IV of the Code of Conduct for Court Personnel?	Canon IV mandates that court personnel must perform official duties properly and with diligence. It underscores the high standards of conduct expected of those working in the judiciary.
What was the role of the Office of the Court Administrator (OCA) in this case?	The OCA investigated the complaint, determined that Beligolo was liable for Simple Neglect of Duty, and recommended a penalty of a fine. The Supreme Court adopted the OCA’s findings but modified the recommended penalty.
What does this case teach us about the duties of public officers?	This case highlights the importance of diligence, efficiency, and accountability among public officers. It emphasizes that even seemingly minor tasks are essential to maintaining the integrity of the justice system.
How does this ruling affect future cases involving neglect of duty?	This ruling reinforces the Supreme Court’s commitment to upholding high standards of conduct within the judiciary. It serves as a reminder to court personnel that neglecting their duties can result in disciplinary action.
What constitutes ‘Conduct Unbecoming of a Court Employee’?	While the complaint initially included this charge, the OCA and the Supreme Court found insufficient evidence to prove that Beligolo’s behavior was irate, sarcastic, or disrespectful. ‘Conduct Unbecoming’ generally refers to behavior that undermines the dignity and integrity of the court.

This case serves as a crucial reminder that diligence and accountability are fundamental to maintaining the integrity of the Philippine judicial system. The Supreme Court’s decision reinforces the importance of even the smallest tasks performed by court personnel. By holding employees accountable for neglect, the Court ensures that the wheels of justice continue to turn smoothly and efficiently. This ruling not only disciplines the individual involved but also sets a clear standard for all those serving within the judiciary.

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: Ione Bethelda C. Ramos v. Reba A. Beligolo, A.M. No. P-19-3919, April 02, 2019