A.M. No. P-93-956 October 30, 1996
OFFICE OF THE COURT ADMINISTRATOR, complainant, vs. ARTURO A. ALAGABAN, Cash Clerk II, Office of the Clerk of Court, MTCC, Davao City and EDUARDO A. ALAGABAN, Clerk III, MTCC, Branch 3, Davao City, respondents.

FACTS

This administrative case originated from an anonymous letter alleging that two court employees, brothers Arturo and Eduardo Alagaban, were drug addicts and mentally unfit for their positions in the Davao City MTCC. An investigation by Executive Judge Augusto Breva and the NBI revealed that both respondents exhibited erratic behavior, including poor concentration, incoherence, frequent absences, and an inability to perform normal work. Arturo was diagnosed with schizophrenia and had been confined in a psychiatric clinic. While evidence of drug addiction was not conclusively proven, the reports detailed severe mental and behavioral issues that disrupted office operations and demoralized other employees. The brothers were nephews of the Clerk of Court, Atty. Adela Alfelor Geverola.

ISSUE

Whether respondents Arturo and Eduardo Alagaban should be dismissed from government service on the grounds of mental incapacity and conduct prejudicial to the best interest of the service.

RULING

Yes. The Court dismissed Eduardo Alagaban from service. The legal logic is grounded on the civil service principle that public office is a public trust, requiring employees to serve with competence, efficiency, and integrity. While the specific charge of drug addiction was not fully substantiated, the investigation established through witness testimonies and medical findings that Eduardo suffered from a mental condition—acute depression with a very low threshold for stress—that rendered him unfit for his duties. His documented behavior, including staring blankly, being incoherent, incurring frequent absences, and demoralizing co-workers, constituted gross inefficiency and conduct prejudicial to the service. The Court emphasized that compassion for an employee’s condition cannot override the paramount need to maintain public service efficiency and the morale of other employees. His continued employment would be unjust to his colleagues, the public, and other qualified applicants. The penalty of dismissal with forfeiture of benefits and disqualification from reemployment was imposed to uphold the integrity and effectiveness of the judiciary. The case against Arturo was deemed moot as he had already been dropped from the rolls due to prolonged absence.