G.R. No. A.M. No. P-1898 April 18, 1979
Fe Bron, complainant, vs. Adoracion J. Delis, respondent.

FACTS

The case originated from a letter-complaint by Fe Bron to the President, referred to the Supreme Court, alleging that respondent Adoracion J. Delis, a stenographer of the Circuit Criminal Court (CCC) in Legazpi City, mortgaged a government typewriter to the Fiesta Hotel in Naga City. The Supreme Court referred the matter to Judge Moises Kallos for investigation. The investigation revealed that in 1974, during a special term of the CCC in Naga City, respondent was issued a Triumph Matura 30 typewriter for official use. She stayed at the Fiesta Hotel during this term and accumulated unpaid hotel bills amounting to P1,778.10.
Upon the conclusion of the special term, respondent, unable to settle her bills, left the government typewriter with the hotel management, which retained it as security for her debt. The typewriter remained in the hotel’s possession until April 1978, when it was recovered by a deputy sheriff following the investigation. The investigation further noted that respondent had collected per diems and allowances for her official stay in 1974. Respondent failed to file a written answer or appear at the formal investigation to contest these factual findings.

ISSUE

Whether respondent Adoracion J. Delis is administratively liable for her actions concerning the government typewriter and her unpaid hotel obligations incurred during official duty.

RULING

Yes, respondent is administratively liable. The Supreme Court found her guilty of grave misconduct, dishonesty, and conduct prejudicial to the best interest of the service, ordering her dismissal. The legal logic is anchored on the fundamental duties of a public officer. Every public official is bound to exercise reasonable skill, diligence, prudence, and caution in the performance of official duties, akin to the standard expected of careful individuals managing their own affairs. Respondent’s actions constituted a blatant violation of this duty.
By using a government-issued typewriter as security for a personal debt, she effectively converted public property for her private benefit, demonstrating dishonesty and gross irresponsibility. Her failure to return the equipment for approximately four years and her concurrent collection of official allowances for the period of her stay, while leaving personal bills unpaid to the detriment of the court’s property, constitute grave misconduct. This behavior erodes public trust and is inherently prejudicial to the service. The Court emphasized that such failure to comply with the duties attached to one’s office warrants severe administrative sanction, irrespective of parallel criminal liability for estafa or swindling. The act of pledging government property for personal debt involves moral turpitude and justifies the ultimate penalty of dismissal from service.