G.R. No. P-03-1710; August 28, 2003
EDGARDO ANGELES, Complainant, vs. BALTAZAR P. EDUARTE, Clerk of Court, Municipal Circuit Trial Court, Bagabag-Diadi, Nueva Vizcaya, Respondent.

FACTS

Complainant Edgardo Angeles sent a letter dated July 28, 2000, to respondent Baltazar P. Eduarte, Clerk of Court, requesting information regarding the court appearances of Atty. Virgil R. Castro on specific dates in September 1999 and related inquiries. The letter was received by respondent on August 8, 2000. Despite a directive in the letter to reply within ten days, respondent failed to respond for over a year.
Consequently, complainant sought the intervention of the Office of the Court Administrator (OCA). On June 20, 2001, Deputy Court Administrator Jose P. Perez directed respondent to act on the letter and submit a report. In his compliance, respondent admitted receiving the letter but explained he overlooked and forgot to answer it because it did not specify the particular case numbers, and he misplaced the document amidst his varied duties. He later found the letter and attached relevant court notices and orders from September 1999 pertaining to cases handled by Atty. Castro.

ISSUE

Whether respondent Clerk of Court is administratively liable for neglect of duty for his failure to promptly act on and respond to the complainant’s letter-request.

RULING

Yes, respondent is liable for neglect of duty. The legal logic centers on the mandatory duty of public officials under Section 5(a) of Republic Act No. 6713 (The Code of Conduct and Ethical Standards for Public Officials and Employees) to act promptly on public requests, requiring a response within fifteen working days from receipt. The Court, through Administrative Circular No. 08-99, has consistently emphasized this obligation for all judiciary personnel to maintain public accountability and trust.
Respondent’s excuses for the delay—that the query lacked specific case numbers, that verification was needed, and that he misplaced the letter—are unacceptable. As the investigating Executive Judge found, the letter specified the exact dates of interest (September 1-6, 1999). Respondent, as Clerk of Court, could have easily directed his staff to check the court calendar and records for those dates, a task feasible within a short period. His failure to do so for over a year constitutes a clear neglect of his administrative responsibilities. As a ranking officer vital to the administration of justice, a Clerk of Court must act promptly and expeditiously on public transactions. This infraction is classified as a light offense under civil service rules. Considering it is his first offense, the penalty of reprimand is appropriate. He is warned that a repetition will be dealt with more severely.