G.R. No. A.M. No. P-05-2095; February 9, 2011
BENIGNO B. REAS, Complainant, vs. CARLOS M. RELACION, Respondent.

FACTS

Complainant Benigno B. Reas, Sheriff IV of the RTC, Branch 23, Cebu City, filed an administrative complaint against respondent Carlos M. Relacion, Clerk III of the RTC, Branch 15, Cebu City, for gross dishonesty and grave misconduct. Reas alleged that his salary check for September 1-15, 2004 (amounting to ₱4,280.00), which was delivered by the Clerk of Court to the Cebu CFI Community Cooperative for loan payment, was “inadvertently surrendered” to Relacion after Relacion harassed the Cooperative to release his own check. Relacion admitted taking the check but did not return it despite demands. A confrontation ensued where Relacion allegedly mauled Reas after Reas refused Relacion’s offer to pay with his Judicial Development Fund check. The check was only paid after the Cooperative confronted Relacion.
In his answer, Relacion denied harassment. He explained that on September 8, 2004, while at the Clerk of Court’s office, a Cooperative representative agreed to give him his salary check. He received a check, folded it without verifying the details, and encashed it at a money changer. Only upon arriving home did he and his wife discover an overpayment (₱4,240.00 received vs. his expected net of ₱1,575.00). The next day, the Cooperative informed him the check belonged to Reas. Relacion attempted to retrieve his own check from the Cooperative to settle the matter but was unsuccessful. He claimed that during a subsequent meeting, Reas punched him first, and he retaliated in self-defense.
The Office of the Court Administrator (OCA) recommended referring the case to the Executive Judge of the RTC, Cebu City. The parties later entered into a compromise agreement where Relacion apologized and paid Reas ₱100.00, leading the Executive Judge to recommend dismissal. The OCA, however, evaluated the case and recommended a fine of ₱2,000.00 for simple misconduct. Relacion subsequently requested the Court to approve the compromise and dismiss the case, citing his impending retirement.

ISSUE

Whether respondent Carlos M. Relacion is administratively liable for his actions concerning the mistaken encashment of complainant’s salary check and the subsequent altercation.

RULING

The Court found respondent Carlos M. Relacion GUILTY OF SIMPLE MISCONDUCT and imposed a FINE OF ₱5,000.00, with a stern warning that a repetition shall be dealt with more severely.
The Court ruled that:
1. Compromise agreements or forgiveness by the complainant do not terminate administrative proceedings. The Court’s disciplinary authority over judicial personnel is exercised in the public interest and cannot be frustrated by private settlements between parties. The paramount concern is the conduct and integrity of the Judiciary.
2. Relacion committed simple misconduct. While there was insufficient proof that he intentionally took Reas’s check, his negligence in failing to verify the check before encashment and his involvement in a physical altercation within court premises constituted improper conduct. As a court employee, he is required by the Code of Conduct for Court Personnel to exhibit the highest sense of honesty and integrity in both official duties and personal dealings. His actions fell short of this standard.
3. The recommended penalty was increased. The Court modified the OCA’s recommended fine from ₱2,000.00 to ₱5,000.00, considering the need to uphold proper decorum and the fact that misconduct by court personnel, even if not in the performance of official duties, tarnishes the judiciary’s integrity.