A.M. No. P-1430. December 29, 1978.
CIRENIA JARAMILLO, complainant, vs. FILOMENA MAGO VISTRO, respondent.

FACTS

Cirenia Jaramillo, the City Librarian of Baguio, filed a sworn complaint against Filomena Mago Vistro, a Deputy Clerk of Court, for discourtesy and misconduct in the course of official duties. The complaint alleged that on September 20, 1976, while Jaramillo was in Vistro’s office to file a cash bail bond for her own case of unjust vexation, Vistro treated her arrogantly and sarcastically. Specifically, Jaramillo claimed that Vistro pressed for an early arraignment date, stating it was court ruling to set it within one week, and ultimately scheduled it for September 27, 1976, despite Jaramillo’s request for more time to consult her lawyer. Jaramillo further alleged that Vistro was improperly assisting the complaining witness in the unjust vexation case, Rosalinda Bautista, in gathering evidence against her.
In her comment, respondent Vistro categorically denied all charges. She asserted that she attended to complainant with courtesy and respect when the latter was brought to her office by a police officer. Vistro supported her defense with affidavits from co-employees and the arresting officer who were present during the incident, all of whom belied Jaramillo’s account. She also submitted records of previous criminal cases filed against Jaramillo.

ISSUE

Whether the charges of discourtesy and misconduct against respondent Deputy Clerk of Court Filomena Mago Vistro are substantiated by evidence.

RULING

The Supreme Court dismissed the complaint and exonerated the respondent, concurring with the findings and recommendation of the investigating judge, Executive Judge Salvador Valdez of the Court of First Instance of Baguio. The legal logic is grounded on the burden of proof in administrative cases; the complainant must substantiate the allegations with substantial evidence. Here, the Court found the charges unsubstantiated. The sworn statements and testimonies of disinterested witnesses present during the incident—co-employees and Patrolman Limmayog—directly contradicted Jaramillo’s claims and supported Vistro’s defense of proper and courteous conduct.
Furthermore, the Court took judicial notice of the complainant’s established propensity for filing unfounded charges, as evidenced by a letter from a library official detailing Jaramillo’s history of lodging baseless complaints and derogatory remarks against numerous co-workers. This pattern of behavior undermined her credibility. Consequently, the Court found no basis to hold the respondent administratively liable. Instead, the Court reprimanded complainant Jaramillo for her reprehensible conduct and admonished her to refrain from filing baseless charges, emphasizing that such actions have no place in the judicial system and waste its resources. The ruling reinforces the principle that court personnel are entitled to the presumption of regularity in the performance of their duties, which can only be overcome by clear and convincing evidence, which was absent in this case.