G.R. No. A.M. No. P-11 April 30, 1976
MANUEL J. BURGOS, petitioner, vs. ZOILA BADUEL, respondent.

FACTS

Zoila Baduel, a stenographic-reporter in the Court of Industrial Relations, Cebu Branch, was charged administratively. The charges included disgraceful conduct for having an illegitimate son prior to government service and not disclosing it in her information sheet; falsification for withholding material facts such as a prior criminal charge for grave oral defamation and a previous dismissal from private employment; and discourtesy/insubordination. The discourtesy allegations detailed several incidents where Baduel shouted at and was disrespectful towards court commissioners, including Atty. Bienvenido Millares and Atty. Magale, when they admonished her for loud conduct and for attempting to sell her transcript of stenographic notes to a party in a pending case.
In her answer, Baduel admitted to having an illegitimate son but claimed the information sheet’s question was misleading. She denied knowledge of the criminal case at the time of filling out the form and argued the insubordination charges should have been filed by the aggrieved parties directly. She also provided explanations for the confrontations, suggesting they stemmed from misunderstandings or misinformation.

ISSUE

Whether respondent Zoila Baduel is administratively liable for the charges of falsification and discourtesy.

RULING

Yes, the Supreme Court found respondent guilty of falsification and discourtesy. On falsification, the Court rejected Baduel’s explanations as untenable. The omission of her illegitimate child, a prior conviction for slight oral defamation, a pending case for grave oral defamation, and her dismissal from previous employment were material facts that reflected on her moral fitness and would have affected her appointment. Her claim of only learning about the defamation case after submitting her information sheet was deemed incredible. These intentional omissions constituted falsification.
Regarding discourtesy, the investigation confirmed that Baduel acted with belligerence and lack of courtesy towards her superiors, Atty. Millares and Atty. Magale, by shouting at them and engaging in heated arguments when corrected. While these acts did not strictly amount to insubordination, they demonstrated a clear want of respect expected of a court employee. The Court considered the extenuating circumstance of a strong recommendation for her retention from her immediate superior, the Presiding Judge, who vouched for her competence and satisfactory service. Consequently, the Court suspended Zoila Baduel for six months without pay, with a warning that future similar offenses would be dealt with more severely.