AM 105; (July 1975) (Digest)
G.R. No. A.M. No. P-105 July 22, 1975
AUREA G. PENALOSA, complainant, vs. LIGAYA P. SALAYON, respondent.
FACTS
This administrative case involves two court employees from the Court of First Instance of Camarines Norte. Deputy Clerk of Court Aurea G. Peñalosa filed a complaint against stenographer Ligaya P. Salayon for allegedly throwing objects at her and using abusive language during an office altercation on January 22, 1971. Salayon filed a counter-complaint against Peñalosa for grave misconduct, alleging that Peñalosa, after a dispute over a missing office chair, slammed a door, broke its glass panel, called Salayon a thief, and hurled a stone that hit Salayon’s forehead. Both parties later filed a joint motion to withdraw their complaints, stating they had amicably settled their dispute.
The Investigating Judge, Isidoro A. Vera, was instructed by the Department of Justice to proceed with the investigation despite the withdrawal. Judge Vera recommended that both parties be reprimanded and warned. However, the Secretary of Justice exonerated Peñalosa and imposed on Salayon a fine of one month’s pay with a reprimand and warning. Salayon sought reconsideration of this decision.
ISSUE
Whether the Secretary of Justice erred in exonerating Deputy Clerk of Court Aurea G. Peñalosa while imposing a penalty solely on Stenographer Ligaya P. Salayon.
RULING
The Supreme Court modified the decision of the Secretary of Justice. The Court found that both parties allowed their emotions to override propriety and decorum, engaging in a physical and verbal altercation within the court premises during office hours. This conduct set a bad example and tarnished the image of the judiciary. The Court emphasized that the subsequent joint withdrawal of complaints indicated mutual culpability in the incident.
The legal logic centers on the principle of equal accountability for misconduct that disrupts court operations and undermines public respect for the judiciary. The Court rejected the disparate treatment, noting that Peñalosa, as a lawyer and a deputy clerk of court, held a higher position and was therefore more obligated to exhibit exemplary conduct and restraint, even in the face of provocation. Her status imposed a greater duty to maintain decorum and set a standard for subordinates. Consequently, imposing a penalty only on Salayon was unjustified. The Court administered upon both Peñalosa and Salayon the penalty of reprimand, with a warning against repeating such offenses.