GR 95574; (August, 1991) (Digest)
March 16, 2026AM MTJ 91 567; (December, 1996) (Digest)
March 16, 2026A.M. No. P-05-2039. May 31, 2006.
Spouses Roman B. Tiples, Jr. and Melchora A. Tiples, Complainants, vs. Evelyn G. Montoyo, Court Stenographer, RTC-Branch 62, Bago City, Negros Occidental, Respondent.
FACTS
Complainants, representing the heirs of the deceased owners of a parcel of land, were inquiring at the Register of Deeds regarding the transfer of title when they were approached by respondent Evelyn G. Montoyo, a Court Stenographer. Montoyo introduced herself as an RTC employee and offered to facilitate the transfer for a package fee of P15,000.00, which the complainants paid in two installments. She assured them the new title would be issued promptly. Later, Montoyo informed the complainants she could not proceed due to unpaid real property taxes and demanded an additional P8,500.00. The complainants refused, demanded the return of their documents and any unspent money, but Montoyo failed to comply.
In her comment, Montoyo admitted offering her services and receiving the money, claiming it was for legitimate expenses like publication. She argued the failure to complete the transfer was due to the complainants’ refusal to pay the transfer tax and that she had returned P3,000.00. She maintained her dealings were private and unrelated to her official functions, thus any liability should be civil, not administrative.
ISSUE
Whether respondent Evelyn G. Montoyo is administratively liable for her actions.
RULING
Yes, respondent is guilty of Simple Misconduct. The Court emphasized that all court employees must uphold the highest standards of honesty and integrity in both their official duties and private conduct to preserve the judiciary’s integrity. By introducing herself as a court employee, Montoyo created the impression she could leverage her position to facilitate the transfer, which induced the complainants to engage her services. This conduct, regardless of her claim that the money was for actual expenses, tarnished the judiciary’s image. Her actions constitute Simple Misconduct, a less grave offense under the Uniform Rules on Administrative Cases. Considering it was her first offense and the recommendation of the Court Administrator, the Court imposed a three-month suspension without pay with a stern warning against future infractions.
