AM P 01 1522; (November, 2001) (Digest)
G.R. No. P-01-1522. November 29, 2001.
Judge Antonio J. Fineza, Presiding Judge, Regional Trial Court of Caloocan City, Branch 131, complainant, vs. Romeo P. Aruelo, Clerk III, RTC, Branch 122, Caloocan City, respondent.
FACTS
Judge Antonio J. Fineza filed an administrative complaint against Clerk III Romeo P. Aruelo for Gross Misconduct and Obstruction of Justice. The charge stemmed from an affidavit by an accused, Juanito Faustino, who claimed that Aruelo and another individual advised him not to attend his arraignment, falsely stating his case was dismissed, and extracted P30,000.00 from him. Aruelo denied the allegations, asserting he only assisted Faustino in preparing a motion to lift a warrant of arrest after the fact, and advised him to secure a genuine medical certificate for his absence.
The case underwent investigation, but proceedings were hampered by the repeated failure to serve subpoenas on the material witness, Faustino. Frustrated by the protracted delay of over two years, complainant Judge Fineza formally withdrew his complaint during a hearing, expressing demoralization and loss of faith in the system. The Investigating Judge consequently recommended dismissal of the complaint but, upon reviewing the records, separately recommended that Aruelo be reprimanded for undue interest in a case outside his sala.
ISSUE
Whether respondent Romeo P. Aruelo should be held administratively liable despite the withdrawal of the complaint by the complainant.
RULING
Yes, the respondent is administratively liable. The withdrawal of an administrative complaint does not automatically result in its dismissal. The Court retains the authority and duty to investigate and decide matters affecting court personnel to preserve public confidence in the judiciary. The withdrawal by Judge Fineza, while noted, does not divest the Court of its disciplinary power.
The legal logic rests on the nature of administrative proceedings as inquiries into the fitness of court employees to remain in public service. These are not private suits but public concerns where the true complainant is the people and the State. Therefore, the desistance of a private complainant or, as in this case, a judicial complainant, does not bind the Court. The Court must examine the records to determine if a breach of the strict standards of conduct for court personnel has occurred.
Based on the evidence, while the serious charge of extortion was not substantiated due to the absence of the main witness, respondent Aruelo’s own admissions established improper conduct. By assisting an accused in a case pending in another branch and involving himself in the preparation of a motion concerning that case, he exhibited undue interest and overstepped the bounds of his duties as a Clerk III. This act constituted simple misconduct, warranting disciplinary action to uphold the integrity of the judicial process. The Court imposed a fine of P2,000.00 with a stern warning.
