AM 05 7 458 RTC; (August, 2005) (Digest)
A.M. No. 05-7-458-RTC. August 25, 2005.
Anonymous Complaint against Sheriff Sales T. Bisnar, Regional Trial Court, Branch 78, Morong, Rizal.
FACTS
An undated anonymous complaint from a Concerned Citizen of Morong, Rizal, charged Sheriff Sales T. Bisnar with conduct unbecoming a court employee. The complainant specifically alleged that Sheriff Bisnar was frequently seen participating in and placing bets on cockfights, sometimes even during official office hours. This behavior, according to the complainant, tarnished the image of the judiciary.
In his Comment dated March 30, 2005, Sheriff Bisnar admitted to attending cockfights but categorically denied doing so during his office hours. The Office of the Court Administrator (OCA), in its Agenda Report, evaluated the case and recommended that Sheriff Bisnar be reminded to be more circumspect in his personal conduct, particularly regarding activities that could reflect poorly on the judiciary.
ISSUE
Whether Sheriff Sales T. Bisnar’s admitted attendance and participation in cockfights constitute improper conduct warranting disciplinary action, notwithstanding the absence of a specific Civil Service rule prohibiting such activity.
RULING
Yes. The Supreme Court found Sheriff Bisnar administratively liable and reprimanded him. The Court emphasized that while no specific Civil Service rule expressly bans government employees from attending cockfights, the standard of conduct for court personnel is far more exacting. The Code of Conduct for Court Personnel mandates that all judiciary employees must act as sentinels of justice, and any act of impropriety immeasurably affects the honor and dignity of the Judiciary and the public’s confidence in it.
The legal logic is anchored on the principle that public office is a public trust. The conduct of all court personnel, from judges to the lowest clerk, must not only be proper but must also be above suspicion to preserve the judiciary’s integrity. The Court ruled that Sheriff Bisnar’s presence at cockfights, an activity often associated with gambling, elicits a bad impression and adversely affects the integrity of the entire judiciary. His actions failed to meet the required standard of being an exemplar of integrity, uprightness, and honesty. Therefore, his admitted conduct constituted impropriety, meriting a reprimand and an admonition to be more circumspect.