AM P 216; (October, 1974) (Digest)
A.M. No. P-216 October 31, 1974
ILUMINADA P. ATIENZA, complainant, vs. ANGELITA L. PERES, respondent.
FACTS
Complainant Iluminada P. Atienza, a cash clerk, filed a verified complaint against respondent Angelita L. Perez, the personnel officer, both of the City Court of Manila, containing seven counts. The Court dismissed six counts as satisfactorily explained but referred the charge for grave misconduct and discourtesy to an executive judge for investigation. The incident in question occurred on October 12, 1973, reportedly stemming from an anonymous letter received by respondent, which she suspected was written by complainant’s sister.
Complainant approached respondent at her office to clarify the matter. The confrontation escalated into a public altercation. The investigating judge found the testimony of a disinterested witness, Mr. Flor Cabrera, to be credible. He testified that complainant initiated the physical confrontation by grabbing folders from respondent’s hands and throwing them at her. Respondent, in turn, threw a liquid at complainant. Both parties engaged in shouting and disorderly conduct within the office premises.
ISSUE
Whether respondent Angelita L. Perez is administratively liable for her conduct during the altercation with complainant.
RULING
Yes, respondent is administratively liable. The Supreme Court emphasized that all government personnel are enjoined to act with self-restraint, civility, and decorum at all times, even when provoked. The investigation conclusively showed that while complainant provoked the incident, respondent also lost her composure. By participating in the shouting match and throwing liquid, she failed to uphold the standard of conduct required of a public servant, especially one in a supervisory position like Personnel Officer.
The Court ruled that such belligerent behavior, which turned office premises into a public spectacle, has no place in the government service. As a personnel officer, respondent had a greater duty to set a proper example. However, considering the provocation, the penalty imposed was a reprimand with a warning against repetition. Simultaneously, the Court required complainant to show cause why she should not also face disciplinary action for her instigating role in the same incident. The decision underscores the imperative for all court employees to maintain professionalism and avoid conduct that undermines the dignity of the judiciary.