A.M. No. 92-10-425-OMB July 15, 1994
RE: OMBUDSMAN CASE NO. OMB-ADM-5-92-0100 (GEMMA LETICIA F. TABLATE v. CAROLINA P. TANJUTCO-SEECHUNG) and OMBUDSMAN CASE NO. OMB-ADM-5-92-0179 (CAROLINA T. SEECHUNG v. GEMMA LETICIA F. TABLATE, ET AL.)

FACTS

The Supreme Court received two consolidated administrative cases from the Office of the Ombudsman involving attorneys Gemma Leticia Tablate and Carolina Tanjutco-Seechung, both employees of the Court of Appeals Reporter’s Division. In her complaint, Seechung charged Tablate with multiple offenses, including grave misconduct, libel, and conduct prejudicial to the service. The core allegation was that Tablate, after being bypassed for a promotion, caused the publication of a newspaper article criticizing the Court of Appeals for alleged misfits in its ranks, thereby diminishing public confidence in the judiciary. Seechung also accused Tablate of misusing public property by having books mailed for personal use and of shouting at her during office confrontations.
In her counter-complaint, Tablate charged Seechung with gross neglect, habitual tardiness, insubordination, and unauthorized engagement in private business during office hours. Tablate alleged that Seechung failed to submit work assignments, was consistently tardy, and spent office time on personal business ventures. She further claimed that Seechung shouted at her when confronted about these infractions. Both parties denied the respective allegations against them.

ISSUE

Whether Attorneys Tablate and Seechung are administratively liable based on the evidence presented.

RULING

The Court, adopting the findings and recommendation of Investigating Justice Angelina S. Gutierrez, found both parties administratively liable. The legal logic rests on the standard of substantial evidence and the high standard of conduct required of court personnel. For Tablate, the publication of the critical newspaper article was substantiated. As an officer of the court, her public criticism of the judiciary, motivated by personal grievance over a promotion, constituted conduct prejudicial to the best interest of the service. It eroded public confidence in the courts, violating the duty of court employees to uphold the judiciary’s dignity. Her act of shouting at a subordinate also constituted discourtesy.
For Seechung, the evidence substantially proved habitual tardiness and engagement in a private export business without the required permission, which are clear violations of civil service rules. Her act of shouting at her superior, Tablate, likewise constituted discourtesy. The Court emphasized that all judiciary personnel must act with propriety and decorum to maintain public respect. The other numerous charges filed by both parties were dismissed for lack of sufficient proof. Consequently, the Court found both attorneys guilty of discourtesy and conduct prejudicial to the best interest of the service, imposing upon each a fine of Five Thousand Pesos (P5,000.00) with a stern warning.