The Supreme Court affirmed the dismissal of a court stenographer for gross misconduct and insubordination. The ruling underscores the stringent standards of behavior expected from judiciary employees. This decision serves as a reminder that court personnel must maintain a professional and respectful demeanor, as their actions reflect on the integrity of the entire judicial system.

When Courtroom Conduct Crumbles: Examining the Limits of Judicial Employee Behavior

This case, Hon. Stela Marie Q. Gandia-Asuncion, et al. v. Lorna M. Martin, arose from a series of incidents involving Lorna M. Martin, a court stenographer at the Municipal Circuit Trial Court (MCTC) in Sta. Ignacia, Tarlac. Her colleagues, including the presiding judge, filed an administrative complaint, citing numerous instances of misconduct, insubordination, and discourtesy. The charges painted a picture of a disruptive employee who frequently clashed with superiors and colleagues, often resorting to offensive language and even threats of violence.

The complainants detailed several specific events showcasing Martin’s problematic behavior. One particularly egregious incident occurred on November 24, 2017, when Martin stormed into Judge Gandia-Asuncion’s chambers, unleashing a torrent of invectives. According to the complaint, Martin screamed,

“Sika nga Judge loklokwen nak, Apay tuwing agpa-correct ak kanyam ti order ket suksukatam, Loko-loko ka, Demonyo, Satanas ka nga talaga nga Judge (You Judge is [sic] fooling me, Why is it that every time I submit my draft orders to you, You make them corrected [sic], You are fooling demon, You really are Satan).”

This outburst was followed by further verbal abuse and an attempt to strike another court employee with a stapler.

The complaints extended beyond this singular incident. Over several years, Martin had received multiple memoranda from Judge Gandia-Asuncion, directing her to explain her misconduct. These memoranda addressed issues ranging from refusing to follow lawful orders to displaying arrogance and disrespect toward colleagues. What’s worse, Martin consistently refused to receive these memoranda, often reacting with further outbursts and defiance. Dioso S. Tomas, the process server, recounted several instances where Martin tore up the memoranda or hurled insults. These actions formed the basis of the charges of gross insubordination and misconduct.

In her defense, Martin denied the charges, claiming they were fabricated. She expressed her disdain for Judge Gandia-Asuncion. However, the Office of the Court Administrator (OCA) found her explanations to be incoherent and evasive. The OCA concluded that her refusal to directly address the allegations amounted to an admission of guilt. This initial assessment set the stage for a more thorough examination by the Supreme Court.

The Supreme Court’s decision rested on a comprehensive assessment of the evidence presented. The Court considered the testimonies of the complainants, the memoranda issued to Martin, and her own admissions and denials. Emphasizing the high standards of conduct required of court personnel, the Court noted that Martin’s behavior violated Canon IV of the Code of Conduct for Court Personnel, which mandates that court employees perform their duties with diligence and courtesy. Her actions, the Court found, constituted gross misconduct and gross insubordination, both serious offenses warranting severe penalties.

The Court referenced the definition of insubordination in Dalmacio-Joaquin v. Dela Cruz, where it was stated that it

“imports a willful or intentional disregard of the lawful and reasonable instructions of the employer.”

Martin’s repeated refusals to accept memoranda and comply with directives from her superiors clearly fit this definition. The Court highlighted that Martin’s actions were not isolated incidents, but rather a pattern of behavior that undermined the authority of the court and created a hostile work environment.

Moreover, the Supreme Court was deeply troubled by Martin’s defiance of its own directives. After issuing a temporary protection order and ordering her preventive suspension, the Court directed her to undergo psychological assessment and counseling. Despite initially agreeing to participate, Martin failed to attend the scheduled videoconference and ignored subsequent attempts to contact her. This open disregard for the Court’s authority further solidified the decision to impose the ultimate penalty.

Given the severity and frequency of Martin’s transgressions, the Supreme Court found that dismissal was the appropriate sanction. The Court also issued a permanent protection order in favor of Judge Gandia-Asuncion and Martin’s other colleagues, prohibiting her from any further acts of violence or harassment. Additionally, Martin was fined P36,000.00 for disobeying the Court’s directive to undergo psychological assessment. These penalties underscored the Court’s commitment to maintaining order and decorum within the judiciary.

The ruling in this case has significant implications for all judiciary employees. It reinforces the principle that court personnel are expected to conduct themselves with professionalism, respect, and obedience to lawful authority. Any deviation from these standards, particularly when it involves gross misconduct or insubordination, can result in severe disciplinary action, including dismissal from the service. The Court’s decision serves as a stern warning to those who would disregard the ethical norms and standards of behavior expected of them as members of the judiciary.

The Court explicitly applied the Amended Rule 140 of the Rules of Court, emphasizing its independence from Civil Service Rules. This underscored the judiciary’s commitment to self-regulation and its determination to enforce its own standards of conduct. The Court’s decision effectively shut down the requests pending before the Office of the Court Administrator for Martin’s transfer because she was dismissed.

FAQs

What was the key issue in this case?	The key issue was whether a court stenographer’s repeated acts of gross misconduct and insubordination warranted dismissal from service. The Supreme Court ultimately ruled in the affirmative, upholding the dismissal.
What specific actions did the court stenographer commit?	The court stenographer committed acts such as verbally abusing her superior, attempting to strike a colleague, refusing to follow lawful orders, and defying a Supreme Court directive to undergo psychological assessment. These actions were deemed to constitute gross misconduct and insubordination.
What is gross misconduct, according to the court?	Gross misconduct involves a flagrant disregard of established rules of conduct and standards of behavior, demonstrating a willful intent to subvert those rules. It also exhibits a lack of professionalism and respect toward the rights of others, contrary to good morals and customs.
What is gross insubordination, according to the court?	Gross insubordination is a refusal to obey an order that a superior officer is entitled to give, involving a willful or intentional disregard of the lawful and reasonable instructions of the employer.
What Code governs the conduct of court personnel?	The Code of Conduct for Court Personnel (CCCP), specifically Canon IV, governs the behavior of court personnel. This code mandates that employees perform their duties with diligence, courtesy, and professionalism.
What penalties can be imposed for gross misconduct and insubordination?	Under Rule 140 of the Revised Rules of Court, as amended, penalties for gross misconduct and insubordination can include dismissal from service, forfeiture of benefits, and disqualification from reinstatement or appointment to any public office.
What is the significance of Amended Rule 140?	Amended Rule 140 establishes an independent disciplinary framework for the judiciary, separate from the Civil Service Rules. It underscores the Supreme Court’s commitment to self-regulation and enforcing its own standards of conduct.
What was the Permanent Protection Order issued in this case?	The Permanent Protection Order prohibited the dismissed court stenographer from threatening, harassing, or contacting her former colleagues and directed her to stay away from them and their residences and place of work.
Why was the court stenographer also fined?	The court stenographer was fined P36,000.00 for disobeying the Supreme Court’s order to undergo a psychological assessment, demonstrating further defiance of authority.

This case serves as a landmark reminder of the stringent ethical and behavioral standards expected of all employees within the Philippine judicial system. The Supreme Court’s decisive action sends a clear message that misconduct and insubordination will not be tolerated, ensuring that the judiciary maintains its integrity and public trust.

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: HON. STELA MARIE Q. GANDIA-ASUNCION v. LORNA M. MARTIN, A.M. No. P-22-042, June 28, 2022