AM P 05 1957; (February, 2005) (Digest)
A.M. No. P-05-1957. February 7, 2005
JUDGE THELMA CANLAS TRINIDAD-PE AGUIRRE, complainant, vs. EDUARDO T. BALTAZAR, Legal Researcher, Regional Trial Court, Branch 129, Caloocan City, respondent.
FACTS
Complainant Judge Thelma Canlas Trinidad-Pe Aguirre filed an administrative complaint against respondent Eduardo T. Baltazar, a Legal Researcher in her branch, for conduct unbecoming a court employee. The complaint stemmed from the respondent’s application for a leave of absence from March 22 to April 20, 2004, to travel abroad. The respondent secured the approval of Executive Judge Silvestre H. Bello, Jr., the pairing judge for Branch 129, instead of seeking the written permission of complainant Judge Aguirre, who was then attending a seminar in Tagaytay City. The judge alleged this act undermined her authority. Prior to this, the judge had already fined the respondent ₱500.00 for disobedience and subsequently issued an order detailing him to the Office of the Clerk of Court for alleged failure to perform his duties.
ISSUE
Whether respondent Eduardo T. Baltazar is administratively liable for conduct unbecoming a court employee for securing his leave approval from the Executive Judge instead of the Presiding Judge.
RULING
The Supreme Court DISMISSED the complaint against respondent Baltazar for lack of merit. The legal logic is anchored on the proper allocation of administrative authority. The Court, through the Office of the Court Administrator, found that the respondent acted in accordance with existing rules. OCA Circular No. 6-2003 allows a court personnel applying for leave to be spent abroad to have the application duly recommended by either the Executive Judge or the Presiding Judge. Since Executive Judge Bello, Jr. was the pairing judge for Branch 129, his approval was valid. Furthermore, the respondent’s leave to visit his ailing parents was not contingent upon the needs of the service under civil service rules, removing the discretion typically afforded to the head of office.
Conversely, the Court found that Judge Aguirre exceeded her authority. The power to impose fines on court personnel and to detail them to another office is vested in the Executive Judge under Administrative Order No. 6, not in a Presiding Judge. Her actions were deemed an overzealous and improper exercise of disciplinary authority. Consequently, the Court ADMONISHED Judge Aguirre to be more circumspect in exercising supervisory authority and WARNED that a repetition would be dealt with more severely. The ruling emphasizes that while judges must supervise personnel to ensure efficient service, such authority must be exercised with temperance and strict adherence to procedural rules to preserve the integrity of the judiciary.