A.M. No. P-18-3792. February 20, 2018. RUTH NADIA N. DE LOS SANTOS, COMPLAINANT, VS. JOSE RENE C. VASQUEZ, SHERIFF IV, REGIONAL TRIAL COURT, BRANCH 41 BACOLOD CITY, NEGROS OCCIDENTAL, RESPONDENT.
FACTS

Complainant Ruth Nadia N. De Los Santos alleged that on July 27, 2015, while confronting the wife of respondent Sheriff Jose Rene C. Vasquez over a debt in a grocery store, respondent suddenly appeared, smelling of liquor, hit her left arm, and threatened her in the vernacular, saying, “Don’t wait that something will happen to you and cause my hand to be stained.” Fearing for her safety, complainant reported the incident to the police. She also asserted that respondent, leveraging his position, had manipulated the service of a writ of execution from a prior collection case she had won against his wife.
In his defense, respondent denied being drunk or hitting the complainant. He claimed he intervened upon seeing complainant and his wife in a heated argument, leading to a verbal exchange where he told complainant, “don’t wait for things to get worse.” He denied manipulating any writ, stating it had already been served by the proper sheriff. The case was referred for investigation by the Executive Judge of the Regional Trial Court.

ISSUE

Whether respondent Sheriff Jose Rene C. Vasquez is administratively liable for his actions towards the complainant.

RULING

Yes, respondent is guilty of Conduct Unbecoming of a Court Employee and is DISMISSED from service. The Court adopted the investigating judge’s factual findings but modified the penalty. The investigation found no evidence for dishonesty or abuse of authority but established respondent’s liability for unbecoming conduct based on his act of slapping complainant’s shoulder and using improper, threatening language.
The legal logic centers on the exacting standards of decorum required of all judiciary personnel. Court employees must be paragons of uprightness in both official and private conduct to preserve the judiciary’s integrity and public trust. Respondent’s physical act and intemperate words, committed during office hours without permission, constituted scandalous behavior that eroded public esteem for the judiciary, tantamount to simple misconduct. Crucially, this was not respondent’s first offense; he had been previously suspended for two months for conduct unbecoming a government employee in a separate case (A.M. No. P-07-2313). Given the prior warning and the repetitive nature of the misconduct, the imposition of the ultimate penalty of dismissal is justified under the Uniform Rules on Administrative Cases, which prescribe dismissal for a second offense of simple misconduct. The penalty serves to uphold the judiciary’s dignity and deter similar transgressions.