G.R. No. A.M. No. P-91-590 & P-93-818. April 29, 1996.
BENJAMIN C. GRATELA, complainant, vs. JOSE P. YONZON, JR., Sheriff IV, RTC, Branch 51, Sorsogon, Sorsogon, respondent.

FACTS

This administrative matter originated from reciprocal complaints between Clerk of Court Benjamin C. Gratela and Deputy Sheriff Jose P. Yonzon, Jr., both of the Regional Trial Court, Branch 51, Sorsogon. In A.M. No. P-91-590, Gratela charged Yonzon with drunkenness, assault, threats, and misconduct. Gratela alleged that on May 6, 1991, Yonzon, appearing drunk, shouted invectives at him, attempted to throw a typewriter, and later pointed a knife at him while threatening to kill him, requiring police intervention. Yonzon denied the accusations, claiming Gratela was the aggressor who first brandished a knife during an argument over a writ of execution. The investigating judge noted conflicting testimonies from witnesses, with some confirming a violent altercation but none conclusively attesting to Yonzon’s drunkenness.
In the consolidated case, A.M. No. P-93-818, Gratela further charged Yonzon with habitual drunkenness and insubordination based on a July 22, 1991 incident where Yonzon allegedly shouted at and challenged him to a fight, even after the presiding judge attempted to pacify him. Yonzon admitted to an argument but claimed Gratela provoked him. The administrative case filed by Yonzon against Gratela (A.M. No. P-91-629) was dismissed due to Gratela’s death.

ISSUE

Whether respondent Jose P. Yonzon, Jr. is administratively liable for the charges against him.

RULING

Yes, the Supreme Court found respondent Yonzon guilty of misconduct. The Court, adopting the findings of the Office of the Court Administrator (OCA), held that Yonzon’s actions during the office altercations constituted improper behavior unbecoming of a court employee. While the evidence for the specific charge of drunkenness in the May 1991 incident was deemed insufficient for a finding, Yonzon’s admitted participation in heated, violent confrontations within court premises was established. The legal logic centers on the standard of decorum required from all judiciary personnel. Court employees must act with strict propriety to maintain the dignity and public trust in the judicial system. Yonzon’s conduct, characterized by shouting matches, threats, and physical aggression during office hours, displayed a gross discourtesy to a superior and a failure of the circumspection demanded of a public official. This behavior degrades the judiciary’s image. The Court modified the OCA’s recommended penalty, imposing a fine of Two Thousand Pesos (P2,000.00) with a stern warning that a repetition would be met with a more severe sanction.