On 25 June 2024, the Supreme Court, in A.M. No. RTJ-23-040 (Formerly OCA IPI No. 20-5081-RTJ), rendered its decision, imposing a fine against an RTC judge for simple misconduct. The case stemmed from an anonymous complaint alleging violations of the “No Noon Break” policy and unauthorized office closures.
In an Anonymous Letter Complaint dated 21 July 2019, submitted to the Executive Judge of and the Office of the Court Administrator (OCA), the complainant claimed that he has been visiting the Branch of the RTC judge to follow-up on the case of a loved one which is pending in the court.
The complainant stated that on multiple occasions, he arrived at the Branch before 11:00 a.m. and found no employees present. On each occasion, the security guard informed him that the judge and staff were out for lunch.
On July 19, 2019, complainant closed arrived at court at around 1:00 p.m., and to his dismay, the Branch was closed. Despite waiting until 4:30 p.m. and witnessing the flag retreat ceremony, the court remained closed. Upon OCA’s investigation, it confirmed that respondents left the court at lunchtime on 19 July 2019, and did not return.
Respondents justified their absence by stating that they had gone to inspect their new office, assist in inventory, and coordinate with relevant government agencies for necessary installations. They argued that this move was necessary to expedite their eventual transfer.
With regard to the claim that Branch was closed on the afternoon of 19 July 2019, they claimed that this was false because the Court Stenographer and Legal Researcher II were at the office for the entire day, as they were instructed to do so. However, affidavits and evidence later revealed that these employees had also vacated the premises.
After evaluating the evidence, the OCA recommended dismissing the case for insufficiency of evidence but sternly warned all respondents to strictly observe official working hours.
The OCA found that while it was established that the Branch was closed for nearly the entire day of July 19, 2019, this did not denote that respondents were guilty of loafing as they were in the site of the new office performing their assigned tasks.
When the Judicial Integrity Board (JIB) reviewed the case, it disagreed with the OCA and recommended that the Judge be held administratively liable for Simple Misconduct due to her poor management of court operations, which disrupted judicial services.
When the case reached the Supreme Court, it concurred with the JIB, holding that the judge’s decision to have nearly her entire staff abandon their posts for office-related errands during working hours was improper and constituted a violation of court rules.
The Court emphasized that judicial duties take precedence over administrative concerns, and that court personnel should not have been required to participate in tasks unrelated to court proceedings during office hours.
As to the court personnel, the Supreme Court dismissed the charges against them as the Court found that they were simply obeying the orders of the Judge. Nonetheless, the Court held that they should be enjoined to advise their presiding judge to do what should be proper and act in accordance with the rules, within the limits of reason and respect.
