G.R. No.: A.M. No. P-02-1575; August 1, 2002
Case Parties: ARMANDO R. CANILLAS, complainant, vs. CORAZON V. PELAYO, Clerk of Court, Municipal Trial Court, Rosales, Pangasinan, respondent.

FACTS

On March 22, 2000, the Office of the Court Administrator (OCA) received an affidavit-complaint from Armando R. Canillas, an associate professor, charging Corazon V. Pelayo, Clerk of Court of the Municipal Trial Court of Rosales, Pangasinan, with Grave Abuse of Authority. Complainant averred that on March 8, 2000, he received a subpoena served by ordinary mail, commanding him to appear before the said court on March 24, 2000. The subpoena bore the court’s embossed seal and respondent’s signature, but the portions indicating the name of the accused, the case number, and the nature of the case were left blank (marked “x x x”). Upon verification at the court on March 14, 2000, a court employee informed complainant that the subpoena was sent merely to compel him to settle an obligation with a certain Salome Jacob, and that a complaint would be filed if he did not settle. Complainant later wrote a letter to the Court Administrator on April 13, 2000, withdrawing his complaint. In her comment, respondent stated that the subpoena was actually intended as an invitation to a mediation conference to give complainant an opportunity to settle his obligation and avoid litigation concerning seventeen potential B.P. 22 complaints. She apologized to complainant and assured the Court she would not repeat the mistake.

ISSUE

Whether respondent Clerk of Court is administratively liable for Grave Abuse of Authority for issuing a subpoena to compel attendance at a mediation conference before any case had been filed in court.

RULING

Yes, the Supreme Court found respondent guilty of Grave Abuse of Authority. The Court agreed with the OCA’s evaluation that respondent’s act of sending a subpoena instead of an invitation letter violated Rule 21, Section 1 of the Rules of Court, which defines a subpoena as a process requiring a person to attend and testify at a hearing, trial, or investigation. Since no case had been filed, the subpoena was improperly used merely as an invitation to a mediation conference. The Court emphasized that the withdrawal of the complaint by the complainant does not warrant dismissal of the administrative case, as disciplinary actions cannot depend on the complainant’s will and complainants are merely witnesses. While respondent claimed she was motivated by a desire to help complainant avoid litigation, her mistake created a stigma and cast doubt on her integrity. The Court reiterated that Clerks of Court, as essential officers in the judicial system, must adhere to the strictest standards of honesty, integrity, and uprightness to safeguard the integrity of the court and maintain public confidence in the administration of justice. Accordingly, the Court imposed a fine of One Thousand Pesos (P1,000.00) on respondent with a stern warning that a repetition would be dealt with more severely.