A.M. No. OCA-00-03; October 4, 2000
LIWAYWAY G. BANIQUED, OIC, Statistical Reports Division, complainant, vs. EXEQUIEL C. ROJAS, Statistician III, respondent.

FACTS

Complainant Liwayway G. Baniqued, Officer-in-Charge of the Statistical Reports Division, Office of the Court Administrator (OCA), charged respondent Exequiel C. Rojas, a Statistician III in the same office, with Grave Misconduct and Slander. The complaint stemmed from an incident on November 4, 1999, where respondent, during office hours and in the presence of other employees, loudly berated and insulted the complainant. He repeatedly ordered her to stop her work adjustments, demanded her resignation, and disparaged her competence as a chief, stating she was overpaid and a disgrace to the division. He also made accusatory remarks about her management of employee leave and shouted at other subordinates.
In his defense, respondent denied being drunk and claimed he was suffering from a headache. He admitted uttering some words but asserted they were not directed at anyone in particular. He apologized to the complainant and vowed the incident would not recur.

ISSUE

Whether respondent Exequiel C. Rojas is administratively liable for his conduct towards his superior and co-employees during office hours.

RULING

Yes, respondent is administratively liable. The Court adopted the findings and recommendation of the Office of the Court Administrator. While the charge that respondent was under the influence of liquor was not proven, his admitted behavior constituted misconduct. His actions—shouting insults, making baseless accusations, and creating a hostile work environment during office hours—demonstrated a high-strung and belligerent attitude utterly unbecoming of a judiciary employee.
The legal logic is grounded in the stringent ethical standards required of all personnel in the administration of justice. The Court emphasized that conduct must always be characterized by propriety and decorum to preserve the judiciary’s integrity and the public’s trust. Respondent’s behavior violated the norms of public accountability and professionalism mandated by Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees). It displayed arrant discourtesy, disrespect towards co-workers and the Court, and a cavalier attitude toward the dignity of court business. Such acts reflect adversely on the judiciary’s good image. Accordingly, the Court imposed a fine of Five Thousand Pesos (₱5,000.00) with a stern warning that a repetition would be dealt with more severely.