OCA IPI No. 20-5005-P. November 29, 2022
JOEL AGULTO SAGUM, COMPLAINANT, VS. JONELL C. CASTILLO, CLERK, (LOCALLY FUNDED EMPLOYEE), BRANCH 89, REGIONAL TRIAL COURT, BACOOR CITY, CAVITE, RESPONDENT.

FACTS

Complainant Joel Agulto Sagum, driver/assistant to Mary Ann B. Ramos-Castro, alleged two incidents in 2019 involving respondent Jonell C. Castillo, who was purportedly working at Branch 89, RTC, Bacoor City. In June 2019, Sagum claimed he witnessed Castro hand money to Castillo after Castillo assured her, “Wag kang mag-alala, ako na ang bahala diyan. Mahahatulan na iyan.” In July 2019, Castillo allegedly asked Sagum, “Nasan ‘yung para sa akin? Paano ‘yung pang-ayos natin sa mga piskal[?]” implying a demand for money to facilitate case proceedings.
In his defense, Castillo vehemently denied the allegations, claiming they were meant to malign his integrity. He also challenged the jurisdiction of the Office of the Court Administrator, asserting he was a casual messenger of the Local Government Unit of Bacoor City and not a clerk of the RTC. The Judiciary Integrity Board, after investigation, recommended dismissal of the complaint for lack of jurisdiction, citing a certification from the OCA that no approved detail order for Castillo as a locally-funded employee at Branch 89 existed in its records.

ISSUE

Whether Jonell C. Castillo should be held administratively liable for the alleged acts of soliciting money and influencing a case.

RULING

The Supreme Court adopted the Judiciary Integrity Board’s recommendation to dismiss the administrative complaint but with modifications. The Court affirmed the lack of jurisdiction over Castillo for administrative discipline, as certifications from the OCA and the Bacoor City HRMD conclusively proved he was not an employee of the Judiciary. Under the Internal Rules of the Judiciary Integrity Board, jurisdiction extends only to officials and employees of the Judiciary; thus, the Board correctly found it could not impose administrative sanctions.
However, the Court ruled that the lack of administrative jurisdiction does not preclude other forms of accountability. Applying the precedent in Anonymous Complaint v. Atty. Zenalfe M. Cuenca, et al., the Court held that any person who purports to act as a judicial employee and engages in conduct that degrades the administration of justice may be subject to contempt proceedings. Castillo’s alleged actions, if proven, directly impugn the integrity of the judicial process and create an appearance of impropriety, which the Court must actively deter to preserve public confidence.
Consequently, while dismissing the administrative case, the Court ordered the Presiding Judge of RTC Bacoor City to refer the complaint to the proper office of the Bacoor City LGU for appropriate action. More significantly, the Court commanded the same Presiding Judge to commence contempt proceedings against Castillo to hold him accountable for his alleged conduct and to determine if he should be barred from future employment in the Judiciary. This ensures that individuals who exploit the perceived authority of the courts are not insulated from consequences.